International
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November 26, 2024
Ukrainian Man Admits To $25M Staffing, Tax Scheme
A Ukrainian man who was recently extradited to the U.S. to face charges that he helped illegally employ immigrants in Florida hotels pled guilty to tax crimes that prosecutors say caused $25 million in tax losses, according to Florida federal court filings.
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November 26, 2024
Jones Walker Welcomes New Commercial, Tax Atty
Jones Walker LLP has added a corporate partner who practices tax law and negotiates, structures and drafts complex merger and acquisition transactions, financings and related contracts and agreements, the firm said.
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November 26, 2024
Australia Will Enact Pillar 2 Minimum Corporate Tax
Australia will institute the Organization for Economic Cooperation and Development's global corporate minimum tax under legislation enacted Tuesday by Parliament.
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November 26, 2024
Many OECD Gov'ts Need More Tax Transparency, Report Says
Peer reviews found nearly half of OECD countries need to improve their legal frameworks for the automatic exchange of financial account information, a decade-old tax transparency system crafted by the organization, while many developing countries received passing grades, according to a report released Tuesday.
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November 26, 2024
OECD Suggests Indonesia Broaden Its Tax Base
Indonesia should broaden its tax base to account for long-term spending pressures like an aging population, the Organization for Economic Cooperation and Development said Tuesday, while also recommending the country pick up the pace on implementing a carbon tax.
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November 26, 2024
UK Gov't Urged To Hold Off On Changes To Inheritance Tax
The British Labour government should hold off on inheritance tax changes for farmers, scheduled to take effect in April, that would make gifts to their heirs taxable if they occur within seven years of the giver's death, a U.K. economics think tank said.
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November 26, 2024
Two Arrested In €19M VAT Fraud Involving VoIP
Authorities arrested two people Tuesday alleging their participation in a €19 million ($19.9 million) value-added tax fraud scheme involving services that let users make phone calls via the internet, the European Public Prosecutor's Office said.
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November 26, 2024
Gov't, US-Saudi Former Pilot Close $1.2M FBAR Suit
A U.S.-Saudi citizen who's been a pilot and luxury airplane consultant settled his $1.2 million dispute with the U.S. government over bank accounts in Switzerland that the IRS said he failed to report.
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November 26, 2024
IRS Confirms Commerce Payments In Chips Tax Credit
Semiconductor development projects that received funding awards from the U.S. Commerce Department's CHIPS incentives program are considered investments that can also take advantage of the advanced manufacturing tax credit, the Internal Revenue Service confirmed Tuesday in guidance.
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November 26, 2024
UK Gov't Urged To Rethink Inheritance Tax Plan For Pensions
The government should consider alternatives to its plan to bring pension assets within the scope of inheritance tax, an online investment company has said, warning that the current proposals could create "financial gridlock."
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November 25, 2024
Aussie Court Affirms R&D Credit Denial For Basketball Shoe
The Australian producer of a basketball shoe cannot count its activities as research and development for tax purposes because of a lack of details on the shoe's development, the Federal Court of Australia ruled Monday.
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November 25, 2024
Ex-DOJ Attorney Joins Moore Tax Law Group In Chicago
The Moore Tax Law Group has brought on a former trial attorney for the U.S. Department of Justice, Tax Division, the firm announced.
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November 25, 2024
UK Releases Deadlines For Top-Up Tax Payments
The U.K. government issued new guidance detailing how multinational corporations should pay domestic and multinational top-up taxes under the Organization for Economic Cooperation and Development's Pillar Two 15% global minimum tax, providing payment deadlines and methods for compliance.
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November 25, 2024
Aussie Gov't Proposes Green Energy Production Tax Credits
Australia's government has unveiled a sweeping new tax incentive program to accelerate investment in renewable hydrogen and critical minerals in an attempt to meet its commitment to a net-zero energy transformation.
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November 25, 2024
Payments To Exxon Unit Taxable, Australian Panel Says
Exxon Mobil unit Esso is liable for tax on monthly payments it received for processing its Australian business partners' petroleum and on an AU$23.4 million ($15.5 million) lump sum payment, a panel at the Federal Court of Australia said, overturning an earlier judgment at the same court.
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November 25, 2024
Feds Violated Atty-Client Rules, Tax Evasion Defendant Says
A Brazilian-American businessman accused of using Swiss bank accounts to hide $20 million from the Internal Revenue Service asked a Florida federal court to dismiss all the charges against him, saying federal prosecutors improperly gained access to information protected by attorney-client privilege.
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November 25, 2024
IRS Corrects Advanced Manufacturing Production Credit Regs
The Internal Revenue Service issued a correction notice Monday concerning final rules for the advanced manufacturing production credit.
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November 25, 2024
Tax Hikes Will Make It Harder To Hire, UK Industry Chief Says
Businesses will hire fewer workers as a result of raising employers' National Insurance contributions, a payroll levy, that was introduced in the autumn budget, the chief of one of Britain's most influential industry groups said Monday.
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November 22, 2024
Trump Taps Hedge Fund Billionaire Bessent To Head Treasury
President-elect Donald Trump on Friday announced that he's selected Scott Bessent, a billionaire hedge fund manager and the founder of Key Square Group, to serve as secretary of the Treasury in his upcoming administration.
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November 22, 2024
IRS Extends Domestic Content Relief For Energy Credits
Nonprofits, tribal governments, public utilities and other tax-exempt groups eligible for a direct cash payment of their clean energy tax credits can get relief from meeting the domestic content requirements tied to those incentives for 2025 and 2026 under IRS guidance released Friday.
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November 22, 2024
Canada Proposing 2-Month GST Holiday For Groceries, Gifts
Canada's government is sending a proposal to its Parliament that would implement a two-month goods-and-services tax holiday starting in mid-December on goods ranging from certain groceries to Christmas trees.
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November 22, 2024
Isle Of Man Parliament Passes OECD's Global Minimum Tax
The Isle of Man's Parliament approved a bill implementing two portions of the Organization for Economic Cooperation and Development's 15% global minimum tax on large multinational entities making at least €750 million ($781 million) annually, starting in 2025.
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November 22, 2024
IRS Ignores Text In $248M Fight, Liberty Global Tells 10th Circ.
The Internal Revenue Service is incorrectly applying the U.S. tax code in denying Liberty Global's claim for $248 million in foreign tax credits tied to its sale of a Japanese affiliate, the telecommunications company told the Tenth Circuit.
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November 22, 2024
Halliburton Omitted Grounds From $35M Refund Suit, US Says
A Texas federal court must dismiss parts of Halliburton's $35 million tax refund lawsuit because the company failed to raise two grounds of relief in its administrative claim for a refund, the U.S. argued.
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November 22, 2024
Taxation With Representation: Stradley Ronon, Davis Polk
In this week's Taxation With Representation, Amcor PLC buys Berry Global Group Inc., AeroVironment buys BlueHalo, Robinhood Markets Inc. acquires TradePMR, and Comcast Corp. spins off a suite of NBCUniversal cable television networks.
Expert Analysis
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This Earth Day, Consider How Your Firm Can Go Greener
As Earth Day approaches, law firms and attorneys should consider adopting more sustainable practices to reduce their carbon footprint — from minimizing single-use plastics to purchasing carbon offsets for air travel — which ultimately can also reduce costs for clients, say M’Lynn Phillips and Lisa Walters at IMS Legal Strategies.
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Cum-Ex Prosecutions Storm Shows No Sign Of Abating
The ongoing trial of Sanjay Shah in Denmark is a clear indicator that efforts remain focused on holding to account the alleged architects and beneficiaries of cum-ex trading, and with these prosecutions making their way across Europe, it is a more turbulent time now than ever, says Niall Hearty at Rahman Ravelli.
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Practicing Law With Parkinson's Disease
This Parkinson’s Awareness Month, Adam Siegler at Greenberg Traurig discusses his experience working as a lawyer with Parkinson’s disease, sharing both lessons on how to cope with a diagnosis and advice for supporting colleagues who live with the disease.
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Why Supreme Court Should Allow Repatriation Tax To Stand
If the U.S. Supreme Court doesn't reject the taxpayers' misguided claims in Moore v. U.S. that the mandatory repatriation tax is unconstitutional, it could wreak havoc on our system of taxation and result in a catastrophic loss of revenue for the government, say Christina Mason and Theresa Balducci at Herrick Feinstein.
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For Lawyers, Pessimism Should Be A Job Skill, Not A Life Skill
A pessimistic mindset allows attorneys to be effective advocates for their clients, but it can come with serious costs for their personal well-being, so it’s crucial to exercise strategies that produce flexible optimism and connect lawyers with their core values, says Krista Larson at Stinson.
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Requiring Leave To File Amicus Briefs Is A Bad Idea
A proposal to amend the Federal Rules of Appellate Procedure that would require parties to get court permission before filing federal amicus briefs would eliminate the long-standing practice of consent filing and thereby make the process less open and democratic, says Lawrence Ebner at the Atlantic Legal Foundation and DRI Center.
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4 Ways To Motivate Junior Attorneys To Bring Their Best
As Gen Z and younger millennial attorneys increasingly express dissatisfaction with their work and head for the exits, the lawyers who manage them must understand and attend to their needs and priorities to boost engagement and increase retention, says Stacey Schwartz at Katten.
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Former Minn. Chief Justice Instructs On Writing Better Briefs
Former Minnesota Supreme Court Chief Justice Lorie Gildea, now at Greenberg Traurig, offers strategies on writing more effective appellate briefs from her time on the bench.
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Stay Interviews Are Key To Retaining Legal Talent
Even as the economy shifts and layoffs continue, law firms still want to retain their top attorneys, and so-called stay interviews — informal conversations with employees to identify potential issues before they lead to turnover — can be a crucial tool for improving retention and morale, say Tina Cohen Nicol and Kate Reder Sheikh at Major Lindsey.
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Neb. Justices Should Weigh IRC Terms In Dividend Tax Case
Nebraska’s highest court, which will hear oral arguments in Precision CastParts v. Department of Revenue on April 1, should recognize that the Internal Revenue Code provides key clues to defining “dividends received or deemed to be received,” and therefore limits Nebraska’s tax on foreign-sourced corporate income, says Joseph Schmidt at Ryan.
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Judicial Independence Is Imperative This Election Year
As the next election nears, the judges involved in the upcoming trials against former President Donald Trump increasingly face political pressures and threats of violence — revealing the urgent need to safeguard judicial independence and uphold the rule of law, says Benes Aldana at the National Judicial College.
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Spartan Arbitration Tactics Against Well-Funded Opponents
Like the ancient Spartans who held off a numerically superior Persian army at the Battle of Thermopylae, trial attorneys and clients faced with arbitration against an opponent with a bigger war chest can take a strategic approach to create a pass to victory, say Kostas Katsiris and Benjamin Argyle at Venable.
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What Recent Study Shows About AI's Promise For Legal Tasks
Amid both skepticism and excitement about the promise of generative artificial intelligence in legal contexts, the first randomized controlled trial studying its impact on basic lawyering tasks shows mixed but promising results, and underscores the need for attorneys to proactively engage with AI, says Daniel Schwarcz at University of Minnesota Law School.