International
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December 19, 2024
UK Adds Pillar 2 Backstop To Finance Bill
The U.K. government introduced amendments to its latest finance bill Thursday that would update its Pillar Two global minimum tax system and add the backstop to the regime known as the undertaxed profits rule.
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December 18, 2024
Skat Fights To Bring New Cum-Ex Fraud Case Against Broker
The Danish tax authority argued at a London appeals court on Wednesday that it should not be blocked from bringing fresh tax fraud claims against an English brokerage, contending that the claims cover new material not already decided in earlier proceedings.
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December 18, 2024
Morrison Foerster Cites Tariffs As Key M&A Variable For 2025
International law firm Morrison Foerster LLP is among those citing President-elect Donald Trump's tariff plans as a key wild card that could affect mergers and acquisitions deal flow in 2025, a Wednesday report from the firm shows.
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December 18, 2024
Dutch Bank Exec Gave IRS Good Tax Tip, DC Circ. Judge Says
D.C. Circuit judges grappled Wednesday with the denial of a whistleblower award to a late Dutch bank executive who tipped off the IRS to tax reporting schemes, with one judge saying during oral arguments that the executive appeared to have handed the agency "gift-wrapped" evidence of wrongdoing.
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December 18, 2024
EU Court Rejects Latest Challenge To Portugal's Tax Clawback
A European court rejected a Brazilian-based company's challenge Wednesday to a European Commission ruling that Portugal must claw back tax breaks provided to companies with no local economic activity because that ran counter to commission-approved policies.
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December 18, 2024
Upcoming IRS Regs Will Have Optional Amount B Pricing
The Internal Revenue Service announced Wednesday that is planning to propose regulations that will give corporations the option to price certain cross-border transactions using a simplified and streamlined approach under a new international tax framework known as Amount B.
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December 18, 2024
EU VAT Gap Rises To €89B Despite Progress, Report Says
Most European countries have made progress toward tackling the compliance gap for value-added tax, but that gap rose to €89.3 billion ($93.6 billion) in 2022 from just under €76 billion in 2021, the European Commission reported Wednesday.
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December 18, 2024
Police Can Seize £2.6M From Influencers Over Unpaid Tax
Police can seize £2.6 million ($3.3 million) in unpaid taxes from internet influencer Andrew Tate and his brother Tristan Tate over millions they made from online businesses, a London court ruled Wednesday.
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December 17, 2024
Texas Judge Won't Pause Block Of Corp. Transparency Law
A Texas federal judge on Tuesday denied the government's request to stay his nationwide block of a corporate transparency law while an appeal is pending, saying his view that Congress lacks the constitutional authority to enact the legislation is likely to prevail at the Fifth Circuit.
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December 17, 2024
Yukos Capital Opposes Stay In $5B Russia Award Suit
The financing arm of Yukos Oil Co. urged a D.C. federal court on Monday not to pause its lawsuit looking to enforce a $5 billion arbitral award against Russia while litigation involving similar issues plays out, saying the Kremlin is needlessly dragging its feet.
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December 17, 2024
Cyprus, Facing EU Pressure, Passes Minimum Tax
Cyprus' unicameral legislature passed a bill implementing the Organization for Economic Cooperation and Development's global minimum tax on large multinational entities, according to a local news report, ending its holdout as the final country facing pressure from the European Union to do so.
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December 17, 2024
NY Urges Justices To Pass On IBM, Disney Royalty Tax Fight
The U.S. Supreme Court should decline to hear appeals by IBM and Disney that claim New York state's tax treatment of royalties received from foreign affiliates resulted in unconstitutional discrimination against interstate commerce, the state told the court Tuesday.
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December 17, 2024
Canadian Cabinet Official Takes Over Finance Minster Role
Canada's intergovernmental affairs minister is now also the country's finance minister following the sudden resignation of the previous official to hold the post, who cited conflicting views with Prime Minister Justin Trudeau about how to respond to U.S. tariff threats.
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December 17, 2024
Trinity International Adds Tax Expert To Paris Office
Trinity International LLP announced the addition of an experienced tax attorney from Dentons to serve as a partner in its Paris office.
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December 17, 2024
Japan Signs Double-Tax Treaty With Turkmenistan
Japan and Turkmenistan have reached an agreement on a double-tax treaty to replace the convention Japan had with the Soviet Union, Japan's Ministry of Finance said Tuesday.
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December 17, 2024
Ireland Could Lose €15B Due To Trump, Central Bank Warns
The Irish government could lose up to €15 billion ($15.7 billion) of this year's corporate tax surplus if the incoming U.S. administration changes policy, the Central Bank of Ireland warned Tuesday.
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December 16, 2024
Mich. Judge Troubled By Scope Of Feds' CTA Data Collection
A federal judge in Michigan said new disclosure requirements for small businesses seem burdensome and intrusive during a Monday hearing focused on the privacy implications of the currently blocked anti-money laundering law.
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December 16, 2024
Aussie R&D Scheme Promoters Hit With $8.7M In Penalties
The Federal Court of Australia ordered an Australian, his tax agent and his companies to pay a total of AU$13.6 million ($8.7 million) in penalties for promoting illegal research and development tax fraud schemes, the Australian Taxation Office announced.
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December 16, 2024
Canadian Finance Minister Resigns Amid Trump Tariff Threats
Canada's deputy prime minister and minister of finance announced Monday that she is resigning from her post, citing conflicting views with Prime Minister Justin Trudeau about how to respond to tariff threats under President-elect Donald Trump's incoming administration.
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December 16, 2024
Work Still Needed To Keep VAT In EU Effective, Group Says
Following the European Union's agreement on a value-added tax reform package, a group of EU VAT experts presented a wide-ranging suite of short- and long-term proposals Monday aimed at making sure the bloc's regime remains effective as the landscape continues to shift.
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December 16, 2024
Cos. Urge Judge To Maintain Injunction On Transparency Law
A Texas federal judge doesn't need to stay his preliminary injunction on the rollout of new corporate transparency rules while the U.S. government's appeal of his decision is pending at the Fifth Circuit, a business lobbying group and others said Monday.
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December 16, 2024
Wyden Bill Would Nix Tax Perks For Private Placement Plans
U.S. Senate Finance Committee Chairman Ron Wyden unveiled legislation Monday that would remove the tax benefits of a special type of private life insurance plan that he said high-net-worth individuals have been abusing to avoid paying taxes on their investments in the policies.
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December 16, 2024
HMRC Chief Defends Record On Fighting Tax Evasion
The chief executive of HM Revenue & Customs told Parliament on Monday that the British tax authority has reduced the level of tax noncompliance in response to claims it needs a better strategy on tax evasion.
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December 16, 2024
Info On Over 1,900 Tax Rulings Swapped In OECD Last Year
Tax jurisdictions within the Organization for Economic Cooperation and Development spontaneously shared information related to over 1,900 tax rulings involving foreign companies in 2023, the OECD said Monday, highlighting the widespread adoption of its transparency framework aimed at mitigating harmful tax practices.
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December 16, 2024
Hong Kong Commits To OECD Crypto Reporting Framework
Hong Kong plans to take part in the Organization for Economic Cooperation and Development's framework for automatically exchanging financial information regarding crypto-assets starting in 2028, the jurisdiction's Inland Revenue Department said.
Expert Analysis
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Why Now Is The Time For Law Firms To Hire Lateral Partners
Partner and associate mobility data from the second quarter of this year suggest that there's never been a better time in recent years for law firms to hire lateral candidates, particularly experienced partners — though this necessitates an understanding of potential red flags, say Julie Henson and Greg Hamman at Decipher Investigative Intelligence.
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Considering Possible PR Risks Of Certain Legal Tactics
Disney and American Airlines recently abandoned certain litigation tactics in two lawsuits after fierce public backlash, illustrating why corporate counsel should consider the reputational implications of any legal strategy and partner with their communications teams to preempt public relations concerns, says Chris Gidez at G7 Reputation Advisory.
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It's No Longer Enough For Firms To Be Trusted Advisers
Amid fierce competition for business, the transactional “trusted adviser” paradigm from which most firms operate is no longer sufficient — they should instead aim to become trusted partners with their most valuable clients, says Stuart Maister at Strategic Narrative.
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Navigating A Potpourri Of Possible Transparency Act Pitfalls
Despite the Financial Crimes Enforcement Network's continued release of guidance for complying with the Corporate Transparency Act, its interpretation remains in flux, making it important for companies to understand potentially problematic areas of ambiguity in the practical application of the law, say attorneys at Sidley.
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How Methods Are Evolving In Textualist Interpretations
Textualists at the U.S. Supreme Court are increasingly considering new methods such as corpus linguistics and surveys to evaluate what a statute's text communicates to an ordinary reader, while lower courts even mull large language models like ChatGPT as supplements, says Kevin Tobia at Georgetown Law.
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Why Attorneys Should Consider Community Leadership Roles
Volunteering and nonprofit board service are complementary to, but distinct from, traditional pro bono work, and taking on these community leadership roles can produce dividends for lawyers, their firms and the nonprofit causes they support, says Katie Beacham at Kilpatrick.
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Firms Must Offer A Trifecta Of Services In Post-Chevron World
After the U.S. Supreme Court’s Loper Bright Enterprises v. Raimondo decision overturning Chevron deference, law firms will need to integrate litigation, lobbying and communications functions to keep up with the ramifications of the ruling and provide adequate counsel quickly, says Neil Hare at Dentons.
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5 Tips To Succeed In A Master Of Laws Program And Beyond
As lawyers and recent law school graduates begin their Master of Laws coursework across the country, they should keep a few pointers in mind to get the most out of their programs and kick-start successful careers in their practice areas, says Kelley Miller at Reed Smith.
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How Law Firms Can Avoid 'Collaboration Drag'
Law firm decision making can be stifled by “collaboration drag” — characterized by too many pointless meetings, too much peer feedback and too little dissent — but a few strategies can help stakeholders improve decision-making processes and build consensus, says Steve Groom at Miles Mediation.
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Litigation Funding Disclosure Key To Open, Impartial Process
Blanket investor and funding agreement disclosures should be required in all civil cases where the investor has a financial interest in the outcome in order to address issues ranging from potential conflicts of interest to national security concerns, says Bob Goodlatte, former U.S. House Representative for Virginia.
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What NFL Draft Picks Have In Common With Lateral Law Hires
Nearly half of law firm lateral hires leave within a few years — a failure rate that is strikingly similar to the performance of NFL quarterbacks drafted in the first round — in part because evaluators focus too heavily on quantifiable metrics and not enough on a prospect's character traits, says Howard Rosenberg at Baretz+Brunelle.
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Replacing The Stigma Of Menopause With Law Firm Support
A large proportion of the workforce is forced to pull the brakes on their career aspirations because of the taboo surrounding menopause and a lack of consistent support, but law firms can initiate the cultural shift needed by formulating thoughtful workplace policies, says Barbara Hamilton-Bruce at Simmons & Simmons.
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Planning Law Firm Content Calendars: What, When, Where
During the slower month of August, law firms should begin working on their 2025 content calendars, planning out a content creation and distribution framework that aligns with the firm’s objectives and maintains audience engagement throughout the year, says Jessica Kaplan at Legally Penned.