International
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November 05, 2024
On The Ground: How Attorneys Are Safeguarding The Election
Attorneys are working tirelessly Tuesday to support citizens and election workers on the final day of voting in what is expected to be one of history's closest and most contentious presidential contests.
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November 05, 2024
EU Secures VAT Reform Deal To Fit Digital Economy
The European Union is preparing to adapt the bloc's value-added tax rules for the growing digital economy, including e-invoicing on cross-border transactions, after a long-awaited agreement announced Tuesday.
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November 04, 2024
2nd Circ. Rejects Man's Challenge To IRS Lien For $4.2M
The U.S. Tax Court correctly found that the IRS appeals office didn't abuse its powers by approving the agency's federal tax lien to collect $4.2 million from a man with a court-ordered payment plan, the Second Circuit said.
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November 04, 2024
Kenya Eyes 300% Tax Increase In Digital Tax Expansion
Kenya is looking at replacing its 1.5% digital services tax with a 6% levy aimed at the country-sourced revenue of a wider set of nonresident digital service providers, including apps for ride-hailing and food delivery, according to a report by the country's Finance Ministry.
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November 04, 2024
Ukrainian Pleads To $11M Tax Fraud, Immigration Scheme
A Ukrainian national charged for immigration fraud and money laundering has pled guilty and could face 20 years in prison, the U.S. Justice Department announced.
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November 04, 2024
Man Loses Extradition Fight Over $9M Romanian Tax Fraud
A man convicted twice of tax fraud in Romania can be extradited despite the fact that a warrant was missing details about his second conviction because those details were later supplied, a London court has ruled.
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November 04, 2024
Justices Won't Hear UBS Suit Over Disclosed Account Info
The U.S. Supreme Court declined Monday to hear a couple's suit accusing UBS of fraudulently flagging an account to the Internal Revenue Service in violation of civil provisions under the Racketeer Influenced and Corrupt Organizations Act.
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November 01, 2024
Previously Taxed Profit Rules Due By Year's End, Official Says
The Internal Revenue Service will publish the first tranche of long-awaited regulations on offshore earnings and profits previously taxed in the U.S. before the end of the year, an agency counsel said Thursday.
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November 01, 2024
Brazil Should Adopt Latest Pillar 2 Safe Harbor, NFTC Says
Brazil should include the latest updates to globally agreed-upon safe harbors in its legislation to enact an international minimum tax agreement known as Pillar Two, according to the National Foreign Trade Council, which said these measures help prevent double taxation.
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November 01, 2024
Couple Tries To Block IRS Summons Issued For Spain
A couple asked a California federal court to block an IRS summons for their financial information issued on behalf of Spain, saying the demand is tantamount to a fishing expedition meant to help the foreign government prosecute them.
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November 01, 2024
Taxation With Representation: Kirkland, Davis Polk, Wachtell
In this week's Taxation with Representation, BC Partners sells its majority equity interest in GardaWorld, Lone Star Funds sells specialty chemicals company AOC to Nippon Paint Holdings, Crescent Biopharma takes GlycoMimetics private, and Francisco Partners buys AdvancedMD from Global Payments.
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November 01, 2024
Danish Tax Agency To Settle With Atty In $2.1B Tax Fraud Suit
Denmark's tax authority has agreed to settle with an attorney whom it has accused of helping clients claim fraudulent tax refunds in a sprawling $2.1 billion case, according to a letter by its attorney in New York federal court.
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November 01, 2024
CFC Dividend Tax Issue Brewing In Exams, IRS Official Says
A memorandum from the IRS chief counsel explaining why a controlled foreign corporation cannot claim a 100% deduction for certain foreign-based earnings was necessary to inform field agents dealing with the issue in the exam process, an agency official said Thursday.
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November 01, 2024
Australia Takes In Record AU$98B In Taxes From Big Cos.
Large corporate entities paid a record of nearly AU$98 billion ($64 billion) in income taxes to Australia in the 2022-23 tax year, a 16.7% increase from the previous year, the Australian Taxation Office said.
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November 01, 2024
UK Private Schools Challenging Plan To Charge VAT On Fees
The Independent Schools Council said Friday it plans to contest the government's decision to levy value-added tax on private school fees beginning in January.
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October 31, 2024
Australian Tax Collection Up 6% To Nearly AU$611B In 2023-24
Australia collected AU$610.6 billion ($402 billion) in taxes in the 2023-24 tax year, a 6% increase over the year prior and AU$19.4 billion above projections, the Australian Taxation Office said.
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October 31, 2024
OECD Starts Process Of Integrating Thailand As Full Member
The Organization for Economic Cooperation and Development has formally begun the accession process for Thailand to become a full member of the Paris-based body.
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October 31, 2024
Oracle Can't Pause $166M Royalty Cases In Australia
Oracle Corp. can't pause three suits in Australia challenging AU$253.5 million ($167 million) in tax penalties while Irish and Australian authorities conduct a mutual agreement procedure, an Australian judge ruled Thursday, saying a judicial ruling in the cases could affect a wider diplomatic dispute over Australia's royalty taxation.
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October 31, 2024
Scam Promoter Who Cost UK £2.6M In Taxes Is Banned
A man who promoted a tax avoidance scam costing the British government tax agency at least £2.6 million ($3.4 million) has been banned by the government from serving as a director of any company for 10 years, the U.K.'s Insolvency Service announced Thursday.
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October 31, 2024
Exxon Entitled To Interest Deduction On Qatar Deal
Exxon Mobil is entitled to an interest expense deduction on payments to Qatar under a natural gas deal, a Texas federal judge ruled, rejecting the U.S. government's classification of an underlying transaction as a royalty rather than a loan.
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October 31, 2024
Treasury Official Previews M&A Details For Corp. AMT Rules
U.S. rulemakers plan to further address how the country's corporate alternative minimum tax applies to transactions including spinoffs and deals that involve a member of a tax consolidated group, a U.S. Treasury Department official said Thursday.
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October 31, 2024
EU Expected To Close Final Digital VAT Deal Next Week
The European Union is close to a final deal on its plan to bring the bloc's value-added tax rules more in line with the digital economy after representatives reached an agreement in principle, the Hungarian presidency of the Council of the EU confirmed Thursday.
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October 31, 2024
Gov't Urged To Reform Tax Charges On Pension Scam Victims
The government should prioritize reform to ensure that victims of pension scams are no longer hit with massive tax bills, an industry body said Thursday.
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October 31, 2024
5 Convicted In €54M VAT Fraud Of 10,000 Cars
A German court convicted five people for taking part in a value-added tax fraud scheme that involved international trade of more than 10,000 cars that caused €53.7 million ($58.3 million) in estimated losses, the European Public Prosecutor's Office said Thursday.
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October 31, 2024
The 2024 Law360 Pulse Leaderboard
Check out the Law360 Pulse Leaderboard to see which firms made the list of leaders in all-around excellence this year.
Hedge Fund Lawyer Denies Role In £1.4B Cum-Ex Fraud
The former top lawyer at a hedge fund accused of defrauding Denmark's tax authority of £1.4 billion ($1.8 billion) told a London trial Monday he had no knowledge of cum-ex trading fraud at the business.
NOL Rules May Retain Favorable Approach, IRS Counsel Says
New proposed regulations governing business net operating losses that could retain a popular provision allowing some businesses expanded use of those losses are a priority to be published next year, a top Internal Revenue Service lawyer said.
Treasury Using Help To Clear Pillar 1 'Logjam,' Official Says
Other executive agencies in President Joe Biden's administration have backed the U.S. Treasury Department in urging negotiators at the Organization for Economic Cooperation and Development to reach a final deal on the international taxing rights overhaul known as Pillar One, a top Treasury official said Thursday.
Featured Stories
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Reeves To Face MPs As Budget Enters Approval Process
Chancellor Rachel Reeves is due to be grilled by senior MPs on Nov. 6 after she presented the Labour government's first Budget for 14 years, which features a £40 billion ($52 billion) tax package that has raised concerns of new pressure on businesses and retirement savers.
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Pillar 2 Likely To Cast Shadow Over US Tax Bill Talks
The international minimum tax agreement known as Pillar Two won't officially factor into upcoming tax bill negotiations in the U.S. Congress, but the global regime's potential grab at U.S. tax revenue could informally influence policy choices.
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UK Capital Gains Hike Casts Shadow Over Gov't LSE Aims
The decision by Chancellor Rachel Reeves to raise the tax paid on gains made when shares are sold could hinder the government's work on making the London Stock Exchange more attractive for stock listings and investors, regulatory experts warn.
Expert Analysis
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Striking A Balance Between AI Use And Attorney Well-Being
As the legal industry increasingly adopts generative artificial intelligence tools to boost efficiency, leaders must note the hidden costs of increased productivity, and work to protect attorneys’ well-being while unlocking AI’s full potential, says Ed Sohn at Factor.
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Empathy In Mediation Offers A Soft Landing For Disputes
Experiencing a crash-landing on a recent flight underscored to me how much difference empathy makes in times of crisis or stress, including during mediation, says Eydith Kaufman at Alternative Resolution Centers.
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How Judiciary Can Minimize AI Risks In Secondary Sources
Because courts’ standing orders on generative artificial intelligence and other safeguards do not address the risk of hallucinations in secondary source materials, the judiciary should consider enlisting legal publishers and database hosts to protect against AI-generated inaccuracies, say attorneys at Lankler Siffert & Wohl.
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How Attorneys Can Break Free From Career Enmeshment
Ambitious attorneys can sometimes experience career enmeshment — when your sense of self-worth becomes unhealthily tangled up in your legal vocation — but taking the time to discover and realign with your core personal values can help you recover your identity, says Janna Koretz at Azimuth Psychological.
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Lawyers With Disabilities Are Seeking Equity, Not Pity
Attorneys living with disabilities face extra challenges — including the need for special accommodations, the fear of stigmatization and the risk of being tokenized — but if given equitable opportunities, they can still rise to the top of their field, says Kate Reder Sheikh, a former attorney and legal recruiter at Major Lindsey & Africa.
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Judicial Committee Best Venue For Litigation Funding Rules
The Advisory Committee on Civil Rules' recent decision to consider developing a rule for litigation funding disclosure is a welcome development, ensuring that the result will be the product of a thorough, inclusive and deliberative process that appropriately balances all interests, says Stewart Ackerly at Statera Capital.
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The Strategic Advantages Of Appointing A Law Firm CEO
The impact on law firms of the recent CrowdStrike outage underscores that the business of law is no longer merely about providing supplemental support for legal practice — and helps explain why some law firms are appointing dedicated, full-time CEOs to navigate the challenges of the modern legal landscape, says Jennifer Johnson at Calibrate Strategies.
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How Cos. Can Build A Strong In-House Pro Bono Program
During this year’s pro bono celebration week, companies should consider some key pointers to grow and maintain a vibrant in-house program for attorneys to provide free legal services for the public good, says Mary Benton at Alston & Bird.
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Home Canning Makes Me A Better Lawyer
Making my own pickles and jams requires seeing a process through from start to finish, as does representing clients from the start of a dispute at the Patent Trial and Appeal Board through any appeals to the Federal Circuit, says attorney Kevin McNish.
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Use The Right Kind Of Feedback To Help Gen Z Attorneys
Generation Z associates bring unique perspectives and expectations to the workplace, so it’s imperative that supervising attorneys adapt their feedback approach in order to help young lawyers learn and grow — which is good for law firms, too, says Rachael Bosch at Fringe Professional Development.
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Congress Can And Must Enact A Supreme Court Ethics Code
As public confidence in the U.S. Supreme Court dips to historic lows following reports raising conflict of interest concerns, Congress must exercise its constitutional power to enact a mandatory and enforceable code of ethics for the high court, says Muhammad Faridi, president of the New York City Bar Association.
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What To Make Of Dueling Corporate Transparency Act Rulings
Although challenges to the Corporate Transparency Act abound — as highlighted by recent federal court decisions from Alabama and Oregon taking opposite positions on its constitutionality — the act is still law, so companies should comply with their filing requirements or face the potential consequences, say attorneys at Lowenstein Sandler.
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Pop Culture Docket: Justice Lebovits On Gilbert And Sullivan
Characters in the 19th century comic operas of Gilbert and Sullivan break the rules of good lawyering by shamelessly throwing responsible critical thought to the wind, providing hilarious lessons for lawyers and judges on how to avoid a surfeit of traps and tribulations, say acting New York Supreme Court Justice Gerald Lebovits and law student Tara Scown.