International

  • November 19, 2024

    G20 To Cooperate On Soft Law For Taxing Ultra-Wealthy

    Leaders of the world's largest economies intend to cooperate on taxing "ultra-high-net-worth individuals" through soft law approaches such as exchanging best practices and creating model policies that address tax avoidance, according to a Group of 20 Nations declaration.

  • November 19, 2024

    Liberty Global Tax Break Based On Void Moves, 10th Circ. Told

    The economic substance doctrine is broad and can invalidate telecommunications company Liberty Global's transaction that led to a $2.4 billion deduction because steps taken to maximize the tax break lacked business purpose, a government attorney told the Tenth Circuit on Tuesday.

  • November 19, 2024

    Austrian Tax Official Tapped To Head Finance Ministry

    The head of the Austrian finance ministry's tax policy and tax law section will take over as the country's temporary finance minister, the ministry announced Tuesday.

  • November 19, 2024

    Spain Committee Sends Min. Tax To Vote Under EU Pressure

    Spain's lower house will vote Thursday on a bill that would follow through on an EU directive to implement the OECD's global corporate minimum tax after it was narrowly approved by a finance committee Tuesday as the country faces pressure from the bloc.

  • 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.

Expert Analysis

  • How New EU Tax And Transfer Pricing Rules May Affect M&A

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    Companies involved in mergers and acquisitions may need to adjust fiscal due diligence procedures to ensure they consider potential far-reaching effects of newly implemented transfer pricing measures, such as newly implemented global minimum tax and European Union anti-tax avoidance directives and proposals, says Patrick Tijhuis at BDO.

  • How Firms Can Ensure Associate Gender Parity Lasts

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    Among associates, women now outnumber men for the first time, but progress toward gender equality at the top of the legal profession remains glacially slow, and firms must implement time-tested solutions to ensure associates’ gender parity lasts throughout their careers, say Kelly Culhane and Nicole Joseph at Culhane Meadows.

  • 7 Common Myths About Lateral Partner Moves

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    As lateral recruiting remains a key factor for law firm growth, partners considering a lateral move should be aware of a few commonly held myths — some of which contain a kernel of truth, and some of which are flat out wrong, says Dave Maurer at Major Lindsey.

  • 6 Pointers For Attys To Build Trust, Credibility On Social Media

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    In an era of information overload, attorneys can use social media strategically — from making infographics to leveraging targeted advertising — to cut through the noise and establish a reputation among current and potential clients, says Marly Broudie at SocialEyes Communications.

  • US-Chile Tax Treaty May Encourage Cross-Border Investment

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    Provisions in the recently effective U.S.-Chile bilateral income tax treaty should encourage business between the two countries, as they reduce U.S. withholding tax on investment income for Chilean taxpayers, exempt certain U.S. taxpayers from Chilean capital gains tax, and clarify U.S. foreign tax credit rules, say attorneys at Kramer Levin.

  • A Post-Mortem Analysis Of Stroock's Demise

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    After the dissolution of 147-year-old firm Stroock late last year shook up the legal world, a post-mortem analysis of the data reveals a long list of warning signs preceding the firm’s collapse — and provides some insight into how other firms might avoid the same disastrous fate, says Craig Savitzky at Leopard Solutions.

  • SG's Office Is Case Study To Help Close Legal Gender Gap

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    As women continue to be underrepresented in the upper echelons of the legal profession, law firms could learn from the example set by the Office of the Solicitor General, where culture and workplace policies have helped foster greater gender equality, say attorneys at Ocean Tomo.

  • Reimagining Law Firm Culture To Break The Cycle Of Burnout

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    While attorney burnout remains a perennial issue in the legal profession, shifting post-pandemic expectations mean that law firms must adapt their office cultures to retain talent, say Kevin Henderson and Eric Pacifici at SMB Law Group.

  • Cayman Islands Off AML Risk Lists, Signaling Robust Controls

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    As a world-leading jurisdiction for securitization special purpose entities, the removal of the Cayman Islands from increased anti-money laundering monitoring lists is a significant milestone that will benefit new and existing financial services customers conducting business in the territory, say lawyers at Walkers Global.

  • The Legal Industry Needs A Cybersecurity Paradigm Shift

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    As law firms face ever-increasing risks of cyberattacks and ransomware incidents, the legal industry must implement robust cybersecurity measures and privacy-centric practices to preserve attorney-client privilege, safeguard client trust and uphold the profession’s integrity, says Ryan Paterson at Unplugged.

  • 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.

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