International
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January 17, 2025
Law360 Names Practice Groups Of The Year
Law360 would like to congratulate the winners of its Practice Groups of the Year awards for 2024, which honor the attorney teams behind litigation wins and significant transaction work that resonated throughout the legal industry this past year.
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January 17, 2025
Law360 Names Firms Of The Year
Eight law firms have earned spots as Law360's Firms of the Year, with 54 Practice Group of the Year awards among them, steering some of the largest deals of 2024 and securing high-profile litigation wins, including at the U.S. Supreme Court.
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January 20, 2025
Gov't Gets Mixed Reception On Inheritance Tax Pension Plans
Proposals by the U.K. government to bring pension assets within the scope of inheritance tax will result in "numerous problems" and raise concerns in their current form, a trade body and consultants warned on Monday.
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January 17, 2025
UK Parliament Calls New Treasury Unit 'Poorly Defined'
A new HM Treasury office set up to scrutinize fiscal policy lacks staff and its purpose is poorly defined, which means it could duplicate the work of other organizations, the U.K. Parliament's Treasury Select Committee said in a report Sunday.
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January 17, 2025
Case Dismissed Against Man Accused Of Concealing Location
A former healthcare executive whose employer had accused him of avoiding CA$1.2 million ($828,000) in Canadian taxes by lying about his location no longer faces legal action, as the parties agreed to dismiss the action.
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January 17, 2025
Hawaii House Bill Seeks Worldwide Combined Reporting
Hawaii would impose a mandatory worldwide combined reporting system for corporations effective next year under a bill filed in the state House of Representatives.
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January 17, 2025
Taxation With Representation: Simpson Thacher, Covington
In this week's Taxation With Representation, Eli Lilly and Co. buys a precision breast cancer program, Applied Digital Corp. enters a financing agreement for its high-performance computing business, Clearwater Analytics buys Enfusion, and Lantheus Holdings Inc. buys Life Molecular Imaging Ltd.
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January 17, 2025
UAE, Russia Reach Agreement On Double-Tax Treaty
Representatives of the United Arab Emirates and Russia signed a draft treaty to prevent double taxation on income and capital, the UAE's state news agency said Friday, despite ongoing international tensions over Russia's war with Ukraine.
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January 17, 2025
Scottish Power Loses £28M Redress Case Against HMRC
Scottish Power lost its appeal against HM Revenue and Customs on Friday, as a tribunal ruled that the energy company was wrong to argue that just over £28 million ($34 million) in redress payments it made after being investigated for regulatory failures was tax-deductible.
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January 16, 2025
Canadian Conservatives Pledge To Kill Capital Gains Hike
The Conservative Party of Canada promised Thursday to ax a capital gains tax increase secured by the administration of outgoing Prime Minister Justin Trudeau, according to a news release shared on social media Thursday by the party's leader and its candidate for Trudeau's position, Pierre Poilievre.
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January 16, 2025
OECD's Global Minimum Tax Takes Effect In Indonesia
Indonesia began implementing the OECD's global minimum tax on multinational entities making over €750 million ($773 million) annually at the start of this year, the country's Ministry of Finance said Thursday.
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January 16, 2025
Madeira Loses EU State Aid Case Over Tax Breaks
Portugal will have to recover money from companies granted reduced tax rates by its autonomous territory Madeira because the taxpayers failed to meet the terms of two European Commission decisions allowing state aid, the European Court of Justice ruled Thursday.
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January 16, 2025
Morrison Foerster Adds Tax Group Co-Chair From Jones Day
Morrison Foerster LLP announced it has added a partner from Jones Day to serve as co-chair of the firm's global tax group in its New York office.
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January 16, 2025
HMRC Cuts Response Time To Tax Info Exchange Requests
HM Revenue & Customs dropped its average response time to international information exchange requests to 127 days from 175 days, well below the international average of 180 days, the U.K. revenue agency said.
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January 16, 2025
IRS Corrects Simplified Foreign Currency Rules
The Internal Revenue Service issued corrections Thursday to finalized regulations that aim to simplify aspects of how corporations determine taxable income or loss with respect to certain affiliates that conduct business in a foreign currency.
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January 16, 2025
Treasury Updates Bonus Energy Tax Credit Safe Harbors
The U.S. Treasury Department provided updates Thursday to safe harbors that clean energy project developers can use to qualify for bonus tax credits for domestically sourcing steel and aluminum parts in response to new trade restrictions on solar products from China by President Joe Biden's administration.
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January 15, 2025
Dems, GOP Willing To Work On Certain Tax Issues, Aides Say
Democrats are willing to work with Republicans on bipartisan issues, such as providing certain treaty-like benefits to Taiwanese residents, retirement issues, and tax administration issues, Democratic and GOP aides for the House Ways and Means and Senate Finance committees said Wednesday.
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January 15, 2025
Former IRS Litigator Joins Jones Day In Boston
Jones Day announced it added an experienced IRS litigator to its Boston office who will work as of counsel in the firm's tax practice.
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January 15, 2025
Legislators Say Transparency Act Defies First Amendment
The Corporate Transparency Act is an unnecessary intrusion into the First Amendment rights of Americans, U.S. Sen. Thom Tillis, R-N.C., and 13 House members told the Supreme Court in seeking to maintain an injunction issued in December.
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January 15, 2025
House Clears US-Taiwan Double Tax Relief Bill
The U.S. House of Representatives overwhelmingly approved legislation Wednesday that would provide Taiwanese businesses in the United States with tax-treaty-like benefits and authorize the White House to negotiate a tax agreement with Taiwan.
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January 15, 2025
Australia Gives Guidance On Foreign-Funded Construction
The Australian Taxation Office laid out a number of key areas that private companies receiving foreign funding from a related party for property or construction projects need to be aware of in order to not run afoul of the country's transfer pricing rules.
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January 15, 2025
HMRC Board Chair Calls Fiscal Rules Nonnegotiable
The U.K. government will not change course on its fiscal rules despite higher borrowing costs from worsening market conditions, the chair of the board of Britain's tax authority told Parliament's Treasury Committee on Wednesday.
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January 15, 2025
Sweden Should Expand, Simplify R&D Tax Credit, Report Says
A government report said Sweden should simplify and expand its research and development tax credit regime and make changes to what is known as its expert tax incentives in order to improve the country's competition and productivity, its Ministry of Finance said Wednesday.
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January 15, 2025
Chile Must Increase Tax Revenue To Cut Into Debt, OECD Says
With Chile's tax revenues making up just 21% of its gross-domestic product, the country needs to boost its revenue through broad changes to its tax regime if it hopes to keep up with rising spending needs, the Organization for Economic Cooperation and Development said Wednesday.
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January 15, 2025
30 Countries' Minimum Taxes Pass First Review, OECD Says
Policies in about 30 countries passed an initial review for compliance with the 15% global minimum tax system, the first batch to reach that milestone, the Organization for Economic Cooperation and Development said Wednesday.
US Guidance On Amount B Carries Potential For Disputes
Recent IRS guidance on a simplified and streamlined transfer pricing method for certain cross-border transactions, known as Amount B, suggests rulemakers want feedback on how it would work if it were made mandatory, but that approach could lead to controversy without global cooperation.
OECD To Release List Of Abusive Transactions Under Pillar 2
The Organization for Economic Cooperation and Development is putting together a list of intercompany transactions that may raise red flags as attempts to undermine an international minimum tax agreement known as Pillar Two, an OECD official said Thursday.
IRS Mulling Widened Early Application Of Offshore Profit Regs
The Internal Revenue Service is considering expanding the early application option for proposed regulations designed to help U.S. multinational corporations properly account for previously taxed earnings and profits, an agency official said Wednesday.
Featured Stories
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US Guidance On Amount B Carries Potential For Disputes
Recent IRS guidance on a simplified and streamlined transfer pricing method for certain cross-border transactions, known as Amount B, suggests rulemakers want feedback on how it would work if it were made mandatory, but that approach could lead to controversy without global cooperation.
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The Tax Angle: GOP Lawmakers Grapple With TCJA Renewal
From a look at Congress setting parameters for consideration of legislation to renew the GOP's 2017 tax overhaul law to other upcoming tax action in the House and Senate, here's a peek into a reporter's notebook on a few of the week's developing tax stories.
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US International Tax Issues to Watch In 2025
As President-elect Donald Trump and Republicans take control of the U.S. government in 2025, policymakers are expected to address changing international provisions in the Internal Revenue Code and reevaluate the country's role in global tax talks. Here, Law360 examines key U.S. international tax policy issues to watch in the new year.
Expert Analysis
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Rethinking Litigation Risk And What It Really Means To Win
Attorneys have a tendency to overestimate litigation risk before summary judgment and underestimate risk after it, but an eight-stage litigation framework can clarify risk at different points and help litigators reassess what true success looks like in any particular case, says Joshua Libling at Arcadia Finance.
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Small Biz Caught In Corporate Transparency Act Crossfire
Despite compliance being put on hold due to a nationwide preliminary injunction, small businesses have been caught in the middle of the legal battle over the Corporate Transparency Act — and confusion over the law's requirements could result in major penalties, say attorneys at Snell & Wilmer.
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No, Litigation Funders Are Not 'Fleeing' The District Of Del.
A recent study claimed that litigation funders have “fled” Delaware federal court due to a standing order requiring disclosure of third-party financing, but responsible funders have no problem litigating in this jurisdiction, and many other factors could explain the decline in filings, say Will Freeman and Sarah Tsou at Omni Bridgeway.
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5 E-Discovery Predictions For 2025 And Beyond
In the year to come, e-discovery will be shaped by new and emerging trends, from the adoption of artificial intelligence provisions in protective orders, to the proliferation of emojis as a source of evidence in contemporary litigation, say attorneys at Littler.
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What's Ahead As Transparency Act Comes To A Crossroads
Synthesizing the contrasting federal district and appellate court rulings on the Corporate Transparency Act’s validity reveals several main areas of debate that will likely remain at issue as challenges to the law continue winding through the courts, say attorneys at Farella Braun.
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7 Ways 2nd Trump Administration May Affect Partner Hiring
President-elect Donald Trump's return to the White House will likely have a number of downstream effects on partner hiring in the legal industry, from accelerated hiring timelines to increased vetting of prospective employees, say recruiters at Macrae.
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E-Discovery Quarterly: Rulings On Custodian Selection
Several recent rulings make clear that the proportionality of additional proposed custodians will depend on whether the custodians have unique relevant documents, and producing parties should consider whether information already in the record will show that they have relevant documents that otherwise might not be produced, say attorneys at Sidley.
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Exploring Venue Strategy For Trump-Era Regulatory Litigation
Litigation will likely play a prominent role in shaping policy outcomes during the second Trump administration, and stakeholders have several tools at their disposal to steer regulatory litigation toward more favorable venues, say attorneys at Covington.
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An Associate's Guide To Career Development In 2025
As the new year begins, associates at all levels should consider establishing career metrics, fostering key relationships and employing other specific strategies to help move through the complexities of the legal profession with confidence and emerge as trailblazers, say EJ Stern and Amanda George at Fractional Law Firm.
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Making The Pitch To Grow Your Company's Legal Team
In a compressed economy, convincing the C-suite to invest in additional legal talent can be a herculean task, but a convincing pitch — supported by metrics and cost analyses — may help in-house counsel justify the growth of their team, say Elizabeth Smith and Roger Garceau at Major Lindsey.
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Tax Court Should Update Framework For Defining Insurance
The U.S. Tax Court's unnecessary determination in Royalty Management Insurance v. Commissioner that a fraudulent transaction did not contain the hallmarks of a legitimate insurance transaction applies an outdated analysis that threatens the captive insurance sector and illustrates the need for a more modern framework to define true insurance, says Matthew Queen at the Queen Firm.
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When US Privilege Law Applies To Docs Made Outside The US
As globalization manifests itself in disputes over foreign-created documents, a California federal court’s recent trademark decision illustrates nuances of both U.S. privilege frameworks and foreign evidentiary protections that attorneys must increasingly bear in mind, say attorneys at Hunton.
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Impact Of Corporate Transparency Act Ambiguity On Banks
Even though banks generally needn't file beneficial ownership information reports, financial institutions must continue to monitor the status of the Corporate Transparency Act and understand its requirements in case the nationwide injunction that was issued against the CTA earlier this month is overturned, say attorneys at Armstrong Teasdale.