International

  • August 21, 2024

    VAT Fraudster Loses Bid To Escape Repaying £1.4M

    A man involved in a £40 million ($52 million) criminal tax fraud scheme has lost a bid to avoid repaying £1.4 million as a London court ruled on Wednesday that he had failed to prove he no longer had hidden assets.

  • August 20, 2024

    UN Dives Into Murky Waters Of Taxing Digital Services

    The United Nations has its sights set on cross-border services in the digital economy as its framework convention on tax takes shape, but it remains unclear how countries will define that broad and hotly contested topic as they work toward a treaty.

  • August 20, 2024

    Temple Law Prof, Kostelanetz Atty To Lead ABA Tax Section

    A longtime professor at the Temple University Beasley School of Law and a seasoned tax controversy partner at Kostelanetz LLP will together helm the American Bar Association Section of Taxation for the 2025-2026 term, the firm announced Tuesday.

  • August 20, 2024

    IRS Tax-Exempt Compliance Unit Work Too Slow, TIGTA Says

    A decision to expand the scope of checks made by the Internal Revenue Service's Tax-Exempt Compliance Unit resulted in cases taking three times as long to close and a decrease in taxpayers reached by more than half, the Treasury Inspector General for Tax Administration said Tuesday.

  • August 20, 2024

    Allen Matkins Tax Group Leader Jumps To Covington In LA

    Covington & Burling LLP has added to its Los Angeles office a partner with more than 20 years of experience who most recently led Allen Matkins Leck Gamble Mallory & Natsis LLP's tax group, describing the new hire as "one of the country's leading authorities on partnership tax."

  • August 20, 2024

    Trade Group Urges Consistency In Pillar 2 Reporting Standard

    The Organization for Economic Cooperation and Development should focus on making sure there is a standardized approach to acquiring the cross-jurisdiction information required for Pillar Two global minimum tax returns while also minimizing the compliance burden, the National Foreign Trade Council said Tuesday.

  • August 20, 2024

    A Deep Dive Into Law360 Pulse's 2024 Women In Law Report

    The legal industry continues to see incremental gains for female lawyers in private practice in the U.S., according to a Law360 Pulse analysis, with women now representing 40.6% of all attorneys and 51% of all associates.

  • August 20, 2024

    These Firms Have The Most Women In Equity Partnerships

    The legal industry still has a long way to go before it can achieve gender parity at its upper levels. But these law firms are performing better than others in breaking the proverbial glass ceiling that prevents women from attaining leadership roles.

  • August 20, 2024

    Aussie Capital Gains Tax Edit May Hit Green Energy, Pros Say

    An Australian proposal to generally broaden the scope of the country's foreign resident capital gains tax regime could end up restricting foreign investment in the renewable energy sector, a group representing accounting professionals in the country said Tuesday.

  • August 20, 2024

    IRS Proposes Update To Qualified Domestic Trust Regs

    The Internal Revenue Service proposed regulations Tuesday that would update federal estate tax rules for estates of decedents passing property to or for the benefit of a noncitizen spouse in a domestic trust in cases where the executor has made an election to be a qualified domestic trust.

  • August 20, 2024

    EU Tweaks Anti-Subsidy Duties On Chinese EVs

    The European Commission said Tuesday that it is adjusting the anti-subsidy duties that it will charge Chinese exporters of electric vehicles, a move that it had provisionally announced at the beginning of July.

  • August 19, 2024

    Eaton Ordered To Give Int'l Employee Records To IRS

    Eaton Corp. must disclose employment records for some European workers in its transfer pricing dispute with the U.S. government because public interest in curtailing tax avoidance outweighs the interest in protecting the workers' privacy, an Ohio federal judge ruled Monday.

  • August 19, 2024

    Danish Gov't Wants Evidence Excluded In $2B Tax Fraud Case

    A New York federal court should exclude some evidence presented by U.S. pension plans accused in what the Danish tax agency is calling a $2.1 billion tax fraud scheme, the agency said.

  • August 19, 2024

    Chile Senate Panel OKs Bank Secrecy, Whistleblower Plans

    Chile's Senate Finance Committee approved changes to a larger tax compliance bill's proposals for lifting the country's bank secrecy laws in certain situations and for creating an anonymous whistleblower process for reporting tax crimes.

  • August 19, 2024

    Treasury Floats Timing Shift For Foreign Currency Accounting

    The U.S. Treasury Department proposed regulations Monday that would adjust the timing for when companies could opt to use the so-called mark-to-market accounting method for gains or losses that arise from foreign currency transactions.

  • August 19, 2024

    Swedish Advisory Body Considering Pillar 2 Updates

    A Swedish advisory council is considering a proposal that would add administrative and other clarifications to the country's implementation of the Organization for Economic Cooperation and Development's global minimum tax on large multinational corporations.

  • August 16, 2024

    Kyocera Says It Doesn't Need Records For R&D Credits

    Multinational electronics maker Kyocera said Friday that it wasn't required to keep any specific paperwork to back up its claim to research tax credits, contrary to the U.S. government's claims, according to a filing in South Carolina federal court.

  • August 16, 2024

    UK Dependency Considering Global Minimum Tax Bills

    Jersey is considering draft legislation that would implement the Organization for Economic Cooperation and Development's 15% minimum tax on multinational entities making over €750 million ($828 million) annually, in line with a declaration from it and other U.K. crown dependencies to do so starting next year.

  • August 16, 2024

    Democratic Gov't Control Could Bolster US' Pillar 2 Plans

    Vice President Kamala Harris and congressional Democrats would likely double down on plans to align the U.S. tax code with the global minimum tax designed by the Organization for Economic Cooperation and Development if they win total control of the federal government in the November elections.

  • August 16, 2024

    UN Votes For Global Services As First Priority Under Tax Pact

    The United Nations voted Friday to make taxation of cross-border services the most prioritized topic for a legally binding agreement to be finalized by late 2027 alongside the organization's framework convention on international tax cooperation.

  • August 16, 2024

    IRS To Let Private Cos. Into Real-Time Biz Audit Program

    The Internal Revenue Service is opening its compliance assurance process real-time audit program to privately held C corporations, including foreign-owned ones, for 2025, the agency announced.

  • August 16, 2024

    Taxation With Representation: Cleary, Kirkland, Skadden

    In this week's Taxation with Representation, Mars Inc. sets a 2024 record with its $36 billion acquisition of Kellanova, Carlyle inks a $3.8 billion purchase with Baxter International Inc., and Performance Food Group Co. agrees to a $2.1 billion cash deal with Cheney Bros. Inc.

  • August 15, 2024

    Doctor Wants Contempt Fine Dropped In Foreign Asset Case

    A doctor who incurred $1.1 million in liabilities for failing to report his foreign bank accounts is asking a Michigan federal court to waive his $20,000 civil contempt fine because the court restricted his only financial assets to paying the liabilities.

  • August 15, 2024

    Tax Pros Navigate Chaos, Rewards In Climate Law's 2nd Year

    Energy tax attorneys have been knee-deep in project finance deals for the past year since the Inflation Reduction Act of 2022 triggered a flurry of clean energy investments, but the work, they say, has been fulfilling as part of broader efforts to save the environment.

  • August 15, 2024

    Taxes Could Be Key To Cutting Crypto Emissions, IMF Says

    The growing environmental impact of crypto-asset mining and related data centers could be mitigated with tax measures aimed directly at such facilities, the International Monetary Fund said Thursday.

Expert Analysis

  • 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.

  • US-Chile Tax Treaty May Encourage Cross-Border Investment

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    Provisions in the recently effective U.S.-Chile bilateral income tax treaty should encourage business between the two countries, as they reduce U.S. withholding tax on investment income for Chilean taxpayers, exempt certain U.S. taxpayers from Chilean capital gains tax, and clarify U.S. foreign tax credit rules, say attorneys at Kramer Levin.

  • A Post-Mortem Analysis Of Stroock's Demise

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    After the dissolution of 147-year-old firm Stroock late last year shook up the legal world, a post-mortem analysis of the data reveals a long list of warning signs preceding the firm’s collapse — and provides some insight into how other firms might avoid the same disastrous fate, says Craig Savitzky at Leopard Solutions.

  • SG's Office Is Case Study To Help Close Legal Gender Gap

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    As women continue to be underrepresented in the upper echelons of the legal profession, law firms could learn from the example set by the Office of the Solicitor General, where culture and workplace policies have helped foster greater gender equality, say attorneys at Ocean Tomo.

  • Reimagining Law Firm Culture To Break The Cycle Of Burnout

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    While attorney burnout remains a perennial issue in the legal profession, shifting post-pandemic expectations mean that law firms must adapt their office cultures to retain talent, say Kevin Henderson and Eric Pacifici at SMB Law Group.

  • Cayman Islands Off AML Risk Lists, Signaling Robust Controls

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    As a world-leading jurisdiction for securitization special purpose entities, the removal of the Cayman Islands from increased anti-money laundering monitoring lists is a significant milestone that will benefit new and existing financial services customers conducting business in the territory, say lawyers at Walkers Global.

  • The Legal Industry Needs A Cybersecurity Paradigm Shift

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    As law firms face ever-increasing risks of cyberattacks and ransomware incidents, the legal industry must implement robust cybersecurity measures and privacy-centric practices to preserve attorney-client privilege, safeguard client trust and uphold the profession’s integrity, says Ryan Paterson at Unplugged.

  • As Promised, IRS Is Coming For Crypto Tax Evaders

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    The IRS is fulfilling its promise to crack down on those who have neglected to pay taxes on cryptocurrency earnings, as demonstrated by recently imposed prison sentences, enforcement initiatives and meetings with international counterparts — suggesting a few key takeaways for taxpayer compliance, say attorneys at BakerHostetler.

  • 5 Reasons Associates Shouldn't Take A Job Just For Money

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    As a number of BigLaw firms increase salary scales for early-career attorneys, law students and lateral associates considering new job offers should weigh several key factors that may matter more than financial compensation, say Albert Tawil at Lateral Hub and Ruvin Levavi at Power Forward.

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