International

  • September 10, 2024

    UK's Capital Gains Tax Should Mirror Labor Rate, Report Says

    Capital gains tax changes should be a key part of the United Kingdom government's October budget statement, a leading British think tank said Tuesday, recommending that the government equalize capital gains tax with the dividend tax and income tax.

  • September 10, 2024

    State Pension Likely To Rise 4% Under Triple Lock

    The U.K. government is likely to push through an inflation-busting increase to the state pension of approximately £460 ($600) a year from April, after official figures revealed on Tuesday a rise in average earnings.

  • September 10, 2024

    Apple Illegally Obtained €13B In State Aid, Top EU Court Rules

    The European Union's highest court ruled on Tuesday that Ireland illegally granted Apple state aid in past tax rulings, requiring the U.S. technology giant to repay €13 billion ($14.3 billion) in back taxes as well as interest.

  • September 09, 2024

    Russia Says DC Circ. Ruling Erodes $5B Award To Yukos

    A recent D.C. Circuit ruling that Spain must comply with $395 million in arbitration awards awarded to Yukos Oil's financing arm undermines the company's $5 billion claim against Russia because the country, unlike Spain, never ratified the international treaty on which the court relied, Russia has told a D.C. federal court.

  • September 09, 2024

    Tax Court's Take Shouldn't Loom Over Kyocera Case, US Says

    The U.S. Tax Court's opinion that allowed a company to treat a gross-up for taxes paid by its foreign subsidiaries as a dividend received goes against what Congress intended and shouldn't be applied to Kyocera's similar claims, the U.S. Department of Justice told a South Carolina federal court.

  • September 09, 2024

    Bradley Arant Adds Katten Partner In Dallas

    Bradley Arant has hired a six-and-a-half-year veteran of Katten Muchin Rosenman LLP who is joining the firm's corporate and securities practice in Dallas as a partner.

  • September 09, 2024

    Australia, Slovenia Reach Deal On Double-Tax Treaty

    Australia and Slovenia have agreed to a treaty to prevent double taxation between the two countries, which would come into force after approval by both countries' legislatures, Australia's Treasury said Monday.

  • September 09, 2024

    EU Should Loosen Merger Rules To Compete, Report Says

    The European Union should loosen its merger rules and reform trade policy and the energy market in order to boost EU competitiveness enough to catch up with the U.S. and China, a former European Central Bank president reported Monday.

  • September 09, 2024

    Tax Compliance Costs Keeps EU Firms Small, Report Says

    The high cost of tax compliance and the challenges presented by differing regulatory environments encourage European companies to stay small, potentially harming the European Union's competitiveness, according to a report by a former European Central Bank head published on Monday.

  • September 09, 2024

    HMRC Fails To Nab £4B In Small-Biz Tax Evasion, Report Says

    HM Revenue & Customs has failed to stop small businesses from dodging more than £4.4 billion ($5.8 billion) in taxes because it lacks a focused strategy to tackle different tax evasion schemes, the U.K.'s National Audit Office reported Monday.

  • September 06, 2024

    Federal Tax Policies To Watch In The Rest Of The Year

    As Congress returns to Washington, D.C., after the August recess, proposals including disaster tax relief and an agreement to provide tax treaty-like benefits to Taiwanese residents could be readied to be included in year-end legislation. Here, Law360 examines federal tax policies to watch during the last four months of 2024.

  • September 06, 2024

    FDII Covers Overseas Services For US Gov't, Memo Says

    Government contractors that provide services to U.S. operations overseas are allowed to claim the deduction for foreign-derived intangible income, the IRS said in one of two internal memos released Friday that address foreign income issues.

  • September 06, 2024

    Broaden Tax Bases For Cleaner Energy Transition, EU Says

    The impact on government revenues from the transition to cleaner energy, including diminishing fossil fuel tax receipts and increased spending on subsidies supporting green technology, necessitates that countries develop broader tax bases, the European Commission said.

  • September 06, 2024

    4 Key Complications 3 Years After Pillar 2

    Three years ago, countries around the world outlined an agreed-upon minimum corporate tax system in an eight-page document that couldn't have foreseen the full scope of complications that later emerged during implementation, including frictions with existing tax laws. Here, Law360 looks at four key issues that countries and multinational corporations are grappling with as Pillar Two turns three.

  • September 06, 2024

    China Complains To WTO About Canada EV Surtaxes

    China is looking for the World Trade Organization to step in to address proposed Canadian surtaxes on imported Chinese electric vehicles, steel and aluminum, taxes that a spokesperson for China's Ministry of Commerce said Friday violate the organization's rules.

  • September 06, 2024

    Taxation With Representation: Debevoise, Bennett, Orrick

    In this week's Taxation With Representation, Verizon reaches a deal to absorb Frontier in a deal worth $20 billion, First Majestic agrees to buy Gatos Silver for $970 million, and Epam Systems inks a $630 million purchase of Neoris.

  • September 06, 2024

    Vialto Partners Member Joins Baker McKenzie As Partner

    Baker McKenzie has hired a tax partner in Washington, D.C., from Vialto Partners, a business consulting firm, the firm announced Thursday.

  • September 06, 2024

    EU Should Align Disclosure Standards, Industry Group Says

    The European Union should align its forthcoming public tax reporting rules with the same systems in use under the Organization for Economic Cooperation and Development's non-public reporting system, the American Chamber of Commerce in the EU said.

  • September 05, 2024

    Unconstitutionality Of Transparency Act Clear, 11th Circ. Told

    A small business group and one of its members have told the Eleventh Circuit that an Alabama federal judge correctly ruled that the Corporate Transparency Act is unconstitutional, so there was no need for them to demonstrate that the law fails to pass constitutional muster.

  • September 05, 2024

    Liberty Global Urges 10th Circ. To Grant $248M Tax Credit

    The U.S. Tax Court improperly applied an Internal Revenue Code provision to some of the $2.8 billion gain from Liberty Global's sale of a Japanese entity, the telecommunications company said in urging the Tenth Circuit to overturn the resulting rejection of a $248 million tax credit.

  • September 05, 2024

    Holland & Knight Appoints Former Perkins Coie Tax Partner

    Holland & Knight LLP appointed a partner to its Portland, Oregon, office who previously served as a partner in energy tax law for Perkins Coie LLP, the firm announced.

  • September 05, 2024

    Sen. Finance Panel To Hold Hearing On Tax Policy, Avoidance

    The Senate Finance Committee will hold a hearing Sept. 12 covering the 2025 tax policy debate and tax avoidance strategies, it announced Thursday.

  • September 05, 2024

    Broad, Low-Rate DST May Placate US, Ex-OECD Chief Tells EU

    The European Union might be able to break an impasse with the U.S. in negotiations on taxing the digital economy by proposing a digital services tax with a wide base and a low rate, former OECD tax chief Pascal Saint-Amans told Paolo Gentiloni, the bloc's economics commissioner.

  • September 05, 2024

    UK Extends Startup Investment Tax Incentives Through 2035

    Two U.K. tax incentives that encourage private investment in small companies in order to boost innovation and otherwise stimulate economic growth have been extended for 10 years, HM Treasury said.

  • September 05, 2024

    Tax Pros Want Aussie PM To Halt Code Of Conduct Changes

    Six groups representing Australian tax professionals and accountants called on the country's prime minister to step in to stop an "unfair" bill updating the code of conduct for tax agent services if discussions with the country's Treasury don't produce what they say are needed changes.

Expert Analysis

  • Stay Interviews Are Key To Retaining Legal Talent

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    Even as the economy shifts and layoffs continue, law firms still want to retain their top attorneys, and so-called stay interviews — informal conversations with employees to identify potential issues before they lead to turnover — can be a crucial tool for improving retention and morale, say Tina Cohen Nicol and Kate Reder Sheikh at Major Lindsey.

  • Neb. Justices Should Weigh IRC Terms In Dividend Tax Case

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    Nebraska’s highest court, which will hear oral arguments in Precision CastParts v. Department of Revenue on April 1, should recognize that the Internal Revenue Code provides key clues to defining “dividends received or deemed to be received,” and therefore limits Nebraska’s tax on foreign-sourced corporate income, says Joseph Schmidt at Ryan.

  • Judicial Independence Is Imperative This Election Year

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    As the next election nears, the judges involved in the upcoming trials against former President Donald Trump increasingly face political pressures and threats of violence — revealing the urgent need to safeguard judicial independence and uphold the rule of law, says Benes Aldana at the National Judicial College.

  • Spartan Arbitration Tactics Against Well-Funded Opponents

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    Like the ancient Spartans who held off a numerically superior Persian army at the Battle of Thermopylae, trial attorneys and clients faced with arbitration against an opponent with a bigger war chest can take a strategic approach to create a pass to victory, say Kostas Katsiris and Benjamin Argyle at Venable.

  • What Recent Study Shows About AI's Promise For Legal Tasks

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    Amid both skepticism and excitement about the promise of generative artificial intelligence in legal contexts, the first randomized controlled trial studying its impact on basic lawyering tasks shows mixed but promising results, and underscores the need for attorneys to proactively engage with AI, says Daniel Schwarcz at University of Minnesota Law School.

  • How FinCEN Proposal Expands RE Transaction Obligations

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    Against a regulatory backdrop foreshadowing anti-money laundering efforts in the real estate sector, the Financial Crimes Enforcement Network's proposed rule significantly expands reporting requirements for certain nonfinanced residential real estate transfers and necessitates careful review, say attorneys at Fried Frank.

  • Litigation Inspiration: A Source Of Untapped Fulfillment

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    As increasing numbers of attorneys struggle with stress and mental health issues, business litigators can find protection against burnout by remembering their important role in society — because fulfillment in one’s work isn’t just reserved for public interest lawyers, say Bennett Rawicki and Peter Bigelow at Hilgers Graben.

  • Unpacking FinCEN's Proposed Real Estate Transaction Rule

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    Phil Jelsma and Ulrick Matsunaga at Crosbie Gliner take a close look at the Financial Crimes Enforcement Network's recently proposed rulemaking — which mandates new disclosures for professionals involved in all-cash real estate deals — and discuss best next steps for the broad range of businesses that could be affected.

  • Think Like A Lawyer: Forget Everything You Know About IRAC

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    The mode of legal reasoning most students learn in law school, often called “Issue, Rule, Application, Conclusion,” or IRAC, erroneously frames analysis as a separate, discrete step, resulting in disorganized briefs and untold obfuscation — but the fix is pretty simple, says Luke Andrews at Poole Huffman.

  • How New EU Tax And Transfer Pricing Rules May Affect M&A

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    Companies involved in mergers and acquisitions may need to adjust fiscal due diligence procedures to ensure they consider potential far-reaching effects of newly implemented transfer pricing measures, such as newly implemented global minimum tax and European Union anti-tax avoidance directives and proposals, says Patrick Tijhuis at BDO.

  • How Firms Can Ensure Associate Gender Parity Lasts

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    Among associates, women now outnumber men for the first time, but progress toward gender equality at the top of the legal profession remains glacially slow, and firms must implement time-tested solutions to ensure associates’ gender parity lasts throughout their careers, say Kelly Culhane and Nicole Joseph at Culhane Meadows.

  • 7 Common Myths About Lateral Partner Moves

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    As lateral recruiting remains a key factor for law firm growth, partners considering a lateral move should be aware of a few commonly held myths — some of which contain a kernel of truth, and some of which are flat out wrong, says Dave Maurer at Major Lindsey.

  • 6 Pointers For Attys To Build Trust, Credibility On Social Media

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    In an era of information overload, attorneys can use social media strategically — from making infographics to leveraging targeted advertising — to cut through the noise and establish a reputation among current and potential clients, says Marly Broudie at SocialEyes Communications.

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