International

  • November 19, 2024

    Airbnb Ireland Puts Aside $1B For Tax Investigations

    Airbnb has put aside €950 million ($1 billion) in Ireland during talks with the Italian Revenue Authority over a tax audit, according to company accounts reported in Irish media.

  • November 19, 2024

    Treasury Finalizes Partnership Tax Credit 'Direct Pay' Regs

    The U.S. Treasury Department finalized regulations Tuesday to make it easier for tax-exempt entities that co-own development projects to qualify for a direct cash payment of clean energy tax credits by electing out of their partnership tax status.

  • November 18, 2024

    Tax Court Won't Reverse On Foreign Reporting Penalties

    The U.S. Tax Court affirmed Monday its position that the IRS lacks authority to assess certain foreign information reporting penalties, denying the agency's request to reverse a ruling that let a Missouri businessowner off the hook for $120,000.

  • November 18, 2024

    EU Members Face Choice Over Trump Tax Stance, Group Says

    Member states of the European Union will have to pick a side if President-elect Donald Trump's incoming administration abandons global tax reform, the Tax Justice Network said Monday.

  • November 18, 2024

    EU Court OKs Making Execs Show Cause To Escape Tax Debt

    It's acceptable under European Union law to require a business director seeking to rid themselves of their company's tax debt to prove they weren't responsible for failing to notify authorities of their inability to pay, the bloc's highest court ruled.

  • November 18, 2024

    Countries Eye Certain Tax Credits To Get Leg Up Under Pillar 2

    The international minimum tax agreement known as Pillar Two is changing how countries compete for corporate investment, in part by prompting some governments to retool their tax credit systems in ways that could edge out jurisdictions with fewer resources.

  • November 18, 2024

    6th Circ. Pauses IRS Summons For Eaton Worker Docs

    The Sixth Circuit said Eaton Corp. doesn't have to comply with an IRS demand to produce performance reviews for its foreign employees until the appellate court decides whether to overturn a decision that the agency's transfer pricing investigation of the multinational power management company outweighed worker privacy concerns.

  • November 18, 2024

    Malta Should Work To Align With OECD Min. Tax, IMF Says

    Despite its election to delay enacting portions of the OECD's global minimum tax plan under a European Union directive, Malta should develop a plan for adjusting its corporate income tax regime instead of waiting out the clock to implement it, the International Monetary Fund said Monday.

  • November 18, 2024

    Allen Matkins Adds Stradley Ronon Tax Co-Chair In NY

    Allen Matkins Leck Gamble Mallory & Natsis LLP has continued growing its New York office with the addition of the co-chair of Stradley Ronon Stevens & Young LLP's tax department, the firm said Monday.

  • November 18, 2024

    Poland Enacts Global Min. Tax After EU Pressure

    Poland officially implemented the global corporate minimum tax spearheaded by the Organization for Economic Cooperation and Development following pressure from the European Union to join the majority of the bloc in doing so.

  • November 18, 2024

    HMRC's £167M Charges To Reuters Group Deemed Lawful

    A London court backed HM Revenue & Customs in a case over more than £167 million ($212 million) in diverted profits tax charges issued to U.K. companies in the Thomson Reuters media group.

  • November 15, 2024

    The Tax Angle: TCJA Debate, S Corp. Compliance

    From a look at congressional lawmakers ramping up their debate over the expiration of the GOP's 2017 tax overhaul law to the IRS' plans to provide more oversight for pass-through businesses and S corporations, here's a peek into a reporter's notebook on a few of the week's developing tax stories.

  • November 15, 2024

    Poor Counsel Led To Unjust Tax Convictions, Justices Told

    A North Carolina actuary asked the U.S. Supreme Court to review a Fourth Circuit decision denying his bid to reverse his 2016 tax fraud convictions, saying the ruling was based on bad decisions made by his then-trial counsel.

  • November 15, 2024

    OECD Dispute Resolution Caseload Drops For First Time

    The number of open dispute resolution cases under the OECD's mutual agreement procedure decreased nearly 4% in 2023, the first time the OECD observed an annual drop in such cases, it said Friday.

  • November 15, 2024

    Taxation With Representation: Cravath, MoFo, Gibson Dunn

    In this week's Taxation With Representation, Cardinal Health takes a majority stake in GI Alliance and acquires Advanced Diabetes Supply Group, Just Eat offloads Grubhub to Wonder Group, Rivian Automotive and Volkswagen Group launch a joint venture, and Ovintiv Inc. buys Montney Basin assets from Paramount Resources Ltd.

  • November 15, 2024

    Authorities Uncover €5M VAT Fraud Involving Chinese Imports

    A European Public Prosecutor's Office investigation uncovered a scheme involving the importation of Chinese textiles into the EU through Greece and headed to the French market that caused an estimated €5.2 million ($5.5 million) in lost value-added taxes and custom duties, the office said Friday.

  • November 15, 2024

    OECD Tax Forum Commits To Transforming Tax Systems

    The OECD's Forum on Tax Administration, made up of representatives from more than 50 tax jurisdictions, agreed to a set of initiatives Friday intended to drive a "transformation" in global tax administration focused on reducing tax gaps and compliance burdens while increasing tax certainty.

  • November 15, 2024

    Ireland Forecast To Gain Budget Surplus From Apple Case

    The Irish government's budget surplus is expected to rise to 4.4% of gross domestic product next year, much of that as a result of the European Court of Justice's ruling against U.S. tech giant Apple, according to an economic forecast published Friday.

  • November 14, 2024

    Widow Owes $613K After Mexican Tax Dodge, US Tells Court

    The widow of a Texas man faces $613,000 in penalties that her husband incurred by failing to report his foreign bank accounts, the U.S. told a federal court, arguing that she participated in a Mexican real estate transaction to avoid paying the penalties he owed.

  • November 14, 2024

    Australia Delays Country-By-Country Reporting Deadlines

    Entities that have country-by-country reporting obligations for the period ending Dec. 31, 2023, received an automatic one-month extension to file such documents, pushing the deadline to the end of January, the Australian Taxation Office said.

  • November 14, 2024

    IRS Asks Court To Toss Woman's Inheritance Tax Penalty Suit

    A woman who missed the deadline for reporting that she received a $350,000 inheritance isn't allowed to sue the IRS for acting arbitrarily in charging her a late penalty because other remedies to her complaint are available to her, the agency told a California federal court Thursday.

  • November 14, 2024

    Australia Bill Seeks To Expand Rules On Reporting Ownership

    Australia's government wants to fight tax avoidance by making owners of equity derivatives disclose significant owners to regulators and investors, expanding access to that information and giving securities regulators new powers to issue freezing orders for noncompliance, the Australian Treasury said Thursday.

  • November 14, 2024

    OECD Sees Carbon Pricing Growth Coming After Crisis

    While the 2022 energy crisis drove down effective carbon excise tax rates and stalled out the percentage of greenhouse gas emissions covered by such taxes or emissions trading systems, the OECD said Thursday that it expects an increase in covered emissions over the next five years.

  • November 14, 2024

    EC Challenges German Capital Gains Tax In EU High Court

    The European Commission said Thursday that it is referring Germany to the Court of Justice of the European Union over the commission's claims that the country's capital gains tax of certain real estate transactions infringes on the free movement of capital.

  • November 14, 2024

    European Police Detain 43 Suspects In €520M VAT Fraud

    European police detained 43 suspects linked to a value-added tax fraud scam valued at €520 million ($550 million) in a cross-border operation against organized crime, law enforcement agencies said Thursday.

Expert Analysis

  • 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.

  • The Pop Culture Docket: Judge Djerassi On Super Bowl 52

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    Philadelphia Court of Common Pleas Judge Ramy Djerassi discusses how Super Bowl 52, in which the Philadelphia Eagles prevailed over the New England Patriots, provides an apt metaphor for alternative dispute resolution processes in commercial business cases.

  • Employee Experience Strategy Can Boost Law Firm Success

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    Amid continuing business uncertainty, law firms should consider adopting a holistic employee experience strategy — prioritizing consistency, targeting signature moments and leveraging measurement tools — to maximize productivity and profitability, says Haley Revel at Calibrate Consulting.

  • 6 Practice Pointers For Pro Bono Immigration Practice

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    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.

  • Lessons From Country Singer's Personal Service Saga

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    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.

  • 7 E-Discovery Predictions For 2024 And Beyond

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    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.

  • 5 Litigation Funding Trends To Note In 2024

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    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.

  • 4 Legal Ethics Considerations For The New Year

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    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.

  • What The Law Firm Of The Future Will Look Like

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    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.

  • 4 PR Pointers When Your Case Is In The News

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    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.

  • Unpacking The Proposed Production Tax Credit Regulations

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    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.

  • 10 Considerations For Litigating A New York Tax Case

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    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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