International

  • January 10, 2025

    Treasury Finalizes Rules For Disregarded Foreign Payments

    The U.S. Treasury Department issued final regulations Friday that are designed to prevent companies from receiving foreign payments in a way that allows them to reduce their overseas taxes without a corresponding increase in U.S. taxable income.

  • January 10, 2025

    Ga. Law Firm Latest To Fight Corp. Transparency Act

    A federal law designed to combat money laundering violates the U.S. Constitution by forcing lawyers to disregard attorney-client privilege, a Georgia lawyer told a federal court, joining a chorus seeking legal action to stop the law.

  • January 10, 2025

    IRS Finalizes Regulations For Taxing Gifts From Expats

    The Internal Revenue Service issued final regulations and guidance Friday for a 2008 tax on gifts and bequests made by current or former U.S. citizens living abroad to U.S. citizens or residents, including through foreign trusts.

  • January 10, 2025

    Taxation With Representation: Kirkland, Davis Polk, Wachtell

    In this week's Taxation With Representation, Constellation acquires Calpine, Cintas seeks a deal with UniFirst Corp., Stryker Corp. acquires Inari Medical Inc., and Paychex Inc. buys Paycor.

  • January 10, 2025

    Group Busted For Dodging $3.6M In Corp. Tax, Poland Says

    Poland's tax authority said Friday that it had identified an organized crime group that used several companies as fronts to make transactions that avoided 15 million złoty ($3.6 million) in corporate tax.

  • January 10, 2025

    Senate Finance Panel To Vet Treasury Nominee Thursday

    The Senate Finance Committee will hold a hearing Thursday to consider the nomination of Scott Bessent to serve as the new U.S. Treasury secretary under the incoming administration, Sen. Mike Crapo, R-Idaho, said Friday.

  • January 10, 2025

    CMS Taps Tax Disputes Specialist From KPMG

    CMS announced that it has appointed a former KPMG director as a partner in its London-based tax practice.

  • January 10, 2025

    Broker Arian Hit With Fine For Cum-Ex Trade Failings

    The finance watchdog said Friday that it has fined broker Arian Financial LLP £289,000 ($354,000) for having inadequate systems and controls against financial crime in a cum-ex dividend trading case.

  • January 09, 2025

    EisnerAmper Adds Tax Pro As Partner In Dallas

    International business adviser EisnerAmper LLC announced it appointed a certified public accountant from Citrin Cooperman Advisors LLC to serve as a tax partner in the firm's private client services group based in Dallas.

  • January 09, 2025

    Sri Lanka Publishes Advance Pricing Agreement Guidance

    Sri Lanka's Inland Revenue Department published guidance for those interested in entering advance pricing agreements, including eligibility requirements and the steps of the confirmation process.

  • January 09, 2025

    UK Supermarkets Fear Higher Costs Amid Tax Changes

    Supermarket companies Marks & Spencer and Tesco reported Thursday that they had high sales figures due to Christmas, but both retailers also said they expect to face higher tax costs in 2025 due to changes to National Insurance, a payroll tax used to fund social programs.

  • January 09, 2025

    Chile Voluntary Disclosure Program Hits Just 15% Of Estimate

    A Chilean program that allowed for the voluntary disclosure of foreign assets in exchange for a favorable tax rate collected just 92.5 billion Chilean pesos ($92.1 million), which was 15.6% of the projected total, the country's tax authority said.

  • January 09, 2025

    Truss Sends Starmer Legal Threat Over Economy Crash Claim

    Former Prime Minister Liz Truss sent a legal letter to Keir Starmer on Thursday demanding that he stop making "false and defamatory" statements that she crashed the economy, claiming that it is damaging her reputation.

  • January 08, 2025

    Pension Plan Official's Estate Excused From Danish Tax Suit

    A New York federal court approved Wednesday an agreement for Denmark's tax authority to settle its claims against the estate of a pension plan official whose plan allegedly defrauded the agency out of $9 million.

  • January 08, 2025

    UK Accounting Firm Adds Tax Partner To Office

    U.K. accounting firm Martin and Co., a part of the Shaw Gibbs LLP group, has appointed a tax expert from Evelyn Partners as a tax partner to its Winchester office.

  • January 08, 2025

    US, Swiss To Give Retirement Plans Lower Dividend Tax Rates

    The Swiss and U.S. competent authorities agreed to provide lower tax rates on dividends for several types of retirement entities such as trusts that run pensions, qualified annuity plans and individual plans under the two countries' tax treaty, the Swiss government said Wednesday.

  • January 08, 2025

    NY Bill Aims To Increase Tax On GILTI, Raise Top Biz Tax Rate

    New York would reduce the amount of global intangible low-taxed income that is exempt from state tax and nearly double the top corporation franchise tax rate under a bill filed Wednesday in the state Senate.

  • January 08, 2025

    Hong Kong Considering OECD Minimum Tax Bill

    Hong Kong would carry out the Organization for Economic Cooperation and Development's 15% global corporate minimum tax for large multinational entities under a legislative bill introduced Wednesday.

  • January 08, 2025

    Kenya Ratifies OECD Tax Treaty Standards

    Kenya ratified the Organization for Economic Cooperation and Development's multilateral convention on base erosion and profit shifting, which updates bilateral tax treaties of its signatories with agreed-upon standards, the OECD said Wednesday.

  • January 07, 2025

    Canada To Keep Collecting New Gains Tax Amid Halt In Gov't

    Canada's tax authority will continue collections of capital gains tax that reflect proposed changes to the levy despite a suspension of Parliament that will hold up the proposal for months, the country's Department of Finance said Tuesday.

  • January 07, 2025

    30 Arrested In Connection With €17M Luxury Car VAT Fraud

    Authorities arrested 30 people after an investigation in Spain and Germany into a €17 million ($17.6 million) value-added tax fraud involving the international trade of luxury cars, the European Public Prosecutor's Office said Tuesday.

  • January 07, 2025

    Baker McKenzie Adds Tax Partners In California And New York

    Baker McKenzie is fortifying its tax practice by hiring a partner in San Francisco with experience in planning tax positions and handling controversies for technology-driven companies and rehiring another in New York who is skilled at state taxes and journalism.

  • January 07, 2025

    Oman Implements Global Minimum Tax

    Large multinational entities making over €750 million ($777 million) annually are now subject to the Organization for Economic Cooperation and Development's 15% corporate global minimum income tax in Oman after the country implemented two portions of the group's standards.

  • January 06, 2025

    Apple Tax Ruling Fuels Most Of Ireland's €12.8B Surplus

    Ireland recorded a €12.8 billion ($13.3 billion) budget surplus in 2024, though all but €1.8 billion of that revenue was the result of the European Union's highest court ordering Apple to repay billions in back taxes and interest, the country's Department of Finance said Monday.

  • January 06, 2025

    Tax Whistleblower Urges High Court To Review $690M Claim

    A whistleblower is asking the U.S. Supreme Court to review his claim for up to $690 million as his share of the $2.3 billion recovered through Internal Revenue Service investigations that he said resulted from his cooperation.

Featured Stories

  • US International Tax Issues to Watch In 2025

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    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.

  • Federal Tax Policy To Watch In 2025

    Stephen K. Cooper

    While Republicans will hold majorities in both chambers of Congress in 2025, internal party divisions and procedural hurdles could complicate the GOP's effort to renew its 2017 tax overhaul law. Here, Law360 details federal tax policy to watch this year.

  • Top International Tax Cases To Watch In 2025

    Natalie Olivo

    Major multinational corporations such as 3M and Coca-Cola will continue to litigate high-stakes international tax cases during 2025, including transfer pricing disputes with billions of dollars on the line and fights against regulations that allegedly exceed the government's authority. Here, Law360 looks at six key international tax cases to follow in the new year.

Expert Analysis

  • 7 Ways 2nd Trump Administration May Affect Partner Hiring

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    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.

  • E-Discovery Quarterly: Rulings On Custodian Selection

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    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.

  • Exploring Venue Strategy For Trump-Era Regulatory Litigation

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    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.

  • An Associate's Guide To Career Development In 2025

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    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.

  • Making The Pitch To Grow Your Company's Legal Team

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    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.

  • Tax Court Should Update Framework For Defining Insurance

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    ​​​​​​​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.

  • When US Privilege Law Applies To Docs Made Outside The US

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    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.

  • Impact Of Corporate Transparency Act Ambiguity On Banks

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    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.

  • 6 Changes I Would Make If I Ran A Law School

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    Reuben Guttman at Guttman Buschner identifies several key issues plaguing law schools and discusses potential solutions, such as opting out of the rankings game and mandating courses in basic writing skills.

  • Firms Still Have The Edge In Lateral Hiring, But Buyer Beware

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    Partner mobility data suggests that the third quarter of this year continued to be a buyer’s market, with the average candidate demanding less compensation for a larger book of business — but moving into the fourth quarter, firms should slow down their hiring process to minimize risks, say officers at Decipher Investigative Intelligence.

  • Think Like A Lawyer: 1 Type Of Case Complexity Stands Out

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    In contrast to some cases that appear complex due to voluminous evidence or esoteric subject matter, a different kind of complexity involves tangled legal and factual questions, each with a range of possible outcomes, which require a “sliding scale” approach instead of syllogistic reasoning, says Luke Andrews at Poole Huffman.

  • Think Like A Lawyer: Note 3 Simple Types Of Legal Complexity

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    Cases can appear complex for several reasons — due to the number of issues, the volume of factual and evidentiary sources, and the sophistication of those sources — but the same basic technique can help lawyers tame their arguments into a simple and persuasive message, says Luke Andrews at Poole Huffman.

  • Litigation Inspiration: Reframing Document Review

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    For attorneys — new ones especially — there is much fulfillment to find in document review by reflecting on how important, interesting and pleasant it can be, says Bennett Rawicki at Hilgers Graben.