International

  • October 21, 2024

    Foreign Currency Regs Need Flexibility, Biz Group Says

    The U.S. Treasury Department should allow taxpayers with foreign personal holding companies to get automatic consent to revoke elections on the treatment of foreign currency gains or losses under proposed regulations to align such elections with rules on so-called mark-to-market accounting, the National Foreign Trade Council said.

  • October 21, 2024

    UK Director's Use Of Tax Planning Data Subject For Retrial

    Whether a director of a U.K. company is liable for a breach of confidence over the misuse of information in marketing a complex tax structure is an issue to be retried, a London court ruled.

  • October 21, 2024

    MVP: Paul Weiss' Brian Krause

    Brian Krause of Paul Weiss Rifkind Wharton & Garrison LLP's tax practice designed a novel tax approach for the merger of World Wrestling Entertainment and Ultimate Fighting Championship, raced to create a tax-free deal in the final days of a Texas "wildcatter" hoping to sell his oil company, and advised Chevron in its $60 billion acquisition of Hess Corp., earning him a spot as one of the 2024 Law360 Tax MVPs.

  • October 21, 2024

    Estonian Tax System Remains Most Competitive, Study Says

    Estonia's tax system was ranked by a conservative think tank as the most competitive out of the Organization for Economic Cooperation and Development's 38 full members for the 11th year in a row, while the U.S. improved to 18th, according to a report Monday.

  • October 21, 2024

    14 Arrested In Poland For $10M VAT Fraud Involving Trucks

    Polish authorities arrested 14 suspects in connection to a value-added tax fraud scheme involving the import of trucks from other European Union member countries that caused losses worth an estimated 40 million Polish zloty ($10 million), the country's revenue agency said Monday.

  • October 21, 2024

    Canada Offers Relief From Surtaxes On Chinese Imports

    Canadian businesses can now apply under certain conditions for relief from surtaxes the country enacted on Chinese-made electric vehicles and some Chinese steel and aluminum products, the country's Department of Finance said.

  • October 21, 2024

    New ABA Tax Chair-Elect Aims To Expand Leadership Paths

    The new chair-elect of the American Bar Association Section of Taxation told Law360 that she wants to broaden the pathways to leadership for members, including those early in their careers, as part of the section's diversity, equity and inclusion initiatives. Here, Megan Brackney shares more about her background and goals for the section.

  • October 18, 2024

    Law360 MVP Awards Go To Top Attys From 74 Firms

    The attorneys chosen as Law360's 2024 MVPs have distinguished themselves from their peers by securing hard-earned successes in high-stakes litigation, complex global matters and record-breaking deals.

  • October 18, 2024

    Iceland, Brazil Agree To Double-Tax Treaty

    Iceland and Brazil reached an agreement on a double-tax treaty that will go into effect once it is passed by their legislatures, Iceland's Foreign Affairs Ministry said.

  • October 18, 2024

    Ending Nonresident Tax Breaks Could Harm UK, Report Says

    The U.K.'s plans to abolish nondomicile tax status for high-net-worth individuals could reduce the country's economic size by nearly £6.5 billion ($8 billion) by 2035, according to recent research.

  • October 18, 2024

    Bahamas' Parliament To Consider Global Min. Tax Bill

    Qualifying businesses in the Bahamas would be subject to one portion of the OECD's 15% global corporate minimum income tax on large multinational entities making over €750 million ($815 million) annually, under legislation sent to the country's Parliament.

  • October 18, 2024

    IRS OKs Rules On Withholding For Pension Payments

    The Internal Revenue Service released final rules Friday covering certain retirement plans' obligation to withhold income tax when they make payments or distributions to taxpayers outside the U.S. starting in 2026.

  • October 18, 2024

    Taxation With Representation: Baker, Simpson, Ropes

    In this week's Taxation With Representation, Lundbeck inks a $2.6 billion cash deal for Longboard, Silver Lake agrees to buy Zuora for $1.7 billion, and PPG and American Industrial Partners reach a $550 million deal.

  • October 17, 2024

    Liberty Global Shouldn't Get $248M Tax Credit, 10th Circ. Told

    Liberty Global distorted the language and statutory scheme of the U.S. tax code's foreign tax credit regulations to falsely claim $248 million in credits, the U.S. government told the Tenth Circuit on Thursday.

  • October 17, 2024

    India's Top Court Allows Bank To Deduct 'Broken' Interest

    Interest that an Indian bank paid for government securities during what is known as the broken period between coupon payment dates is tax-deductible, the Supreme Court of India ruled, overturning a lower court.           

  • October 17, 2024

    Financial Crime Body To Focus On High-Income Countries

    An intergovernmental task force updated Thursday its criteria for placing countries on its list of those with deficiencies in their anti-money laundering and terrorist financing systems in order to focus on higher-income countries, which it said pose a higher risk than low-income countries.

  • October 17, 2024

    Swedish VAT Exemption Threshold Applies Cross-Border

    Sweden's coming increase in the country's threshold for when businesses must begin collecting value-added tax will apply to certain companies based in other European Union member countries for their Swedish operations and to Swedish companies operating in other EU member countries, Sweden's legislature said.

  • October 17, 2024

    Vestager Urges EU Politicians To Push Ahead With Pillar 1

    European Union competition chief Margrethe Vestager urged EU politicians Thursday to push ahead with work to finalize the Pillar One plan to redistribute taxing rights among countries.

  • October 17, 2024

    Polsinelli Hires McDermott Tax Counsel In DC

    Polsinelli PC has hired an attorney who joined the firm's tax group as a shareholder after 12 and a half years with McDermott Will & Emery LLP.

  • October 17, 2024

    EU Frequent Flyer Tax Could Raise €64B, Think Tank Says

    The European Union could raise an estimated €63.6 billion ($68.9 billion) in revenue by taxing frequent flyers, according to a think tank report published Thursday.

  • October 16, 2024

    Utah Groups Can't Scrap Corporate Transparency, US Says

    A Utah federal court hasn't seen sufficient evidence to block the Corporate Transparency Act's disclosure requirements in presentations by an off-the-grid community, an online meat market and a trade group for cattle producers that have sued over the statute, the federal government said.

  • October 16, 2024

    Japan Signs Double-Tax Treaty With Armenia

    Japan and Armenia 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 Wednesday.

  • October 16, 2024

    Spain's High Court Annuls Rulings Denying R&D Deductions

    Spain's Supreme Court overturned a lower court's ruling that sided with a decision from revenue officials to ignore a report from the country's science ministry when denying corporate tax deductions for research and development.

  • October 16, 2024

    Swedish Parliament To Consider Global Min. Tax Amendments

    Sweden's government sent draft amendments regarding the country's implementation of the Organization for Economic Cooperation and Development's 15% global corporate minimum tax to its Parliament for consideration, the country's Ministry of Finance said.

  • October 16, 2024

    Switzerland Enshrines Ability To Tax Certain Telecommuters

    Switzerland has ensured it will be able to tax employees' earned income if they telework in their country of residence for an employer based in Switzerland — under certain circumstances — starting in 2025, the country's executive body said Wednesday.

Expert Analysis

  • A Look At New IRS Rules For Domestically Controlled REITs

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    The Internal Revenue Services' finalized Treasury Regulations addressing whether real estate investment trusts qualify as domestically controlled adopt the basic structure of previous proposals, but certain new and modified rules may mitigate the regulations' impact, say attorneys at Simpson Thacher.

  • E-Discovery Quarterly: Recent Rulings On Text Message Data

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    Electronically stored information on cellphones, and in particular text messages, can present unique litigation challenges, and recent court decisions demonstrate that counsel must carefully balance what data should be preserved, collected, reviewed and produced, say attorneys at Sidley.

  • Don't Use The Same Template For Every Client Alert

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    As the old marketing adage goes, consistency is key, but law firm style guides need consistency that contemplates variety when it comes to client alert formats, allowing attorneys to tailor alerts to best fit the audience and subject matter, says Jessica Kaplan at Legally Penned.

  • Think Like A Lawyer: Follow The Iron Rule Of Trial Logic

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    Many diligent and eager attorneys include every good fact, point and rule in their trial narratives — spurred by the gnawing fear they’ll be second-guessed for leaving something out — but this approach ignores a fundamental principle of successful trial lawyering, says Luke Andrews at Poole Huffman.

  • The Art Of Asking: Leveraging Your Contacts For Referrals

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    Though attorneys may hesitate to ask for referral recommendations to generate new business, research shows that people want to help others they know, like and trust, so consider who in your network you should approach and how to make the ask, says Rebecca Hnatowski at Edwards Advisory.

  • Unpacking The Bill To Extend TCJA's Biz-Friendly Tax Breaks

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    Attorneys at Skadden examine how a bipartisan bill currently being considered by the U.S. Senate to save the Tax Cuts and Jobs Act's tax breaks for research and development costs, and other expiring business-friendly provisions, would affect taxpayers.

  • Deciding What Comes At The End Of WTO's Digital Tariff Ban

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    Companies that feel empowered by the World Trade Organization’s recent two-year extension of the ban on e-commerce tariffs should pay attention to current negotiations over what comes after the moratorium expires, as these agreements will define standards in international e-commerce for years to come, say Jan Walter, Hannes Sigurgeirsson and Kulsum Gulamhusein at Akin Gump.

  • 4 Ways To Refresh Your Law Firm's Marketing Strategy

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    With many BigLaw firms relying on an increasingly obsolete marketing approach that prioritizes stiff professionalism over authentic connection, adopting a few key communications strategies to better connect with today's clients and prospects can make all the difference, say Eric Pacifici and Kevin Henderson at SMB Law.

  • This Earth Day, Consider How Your Firm Can Go Greener

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    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.

  • Cum-Ex Prosecutions Storm Shows No Sign Of Abating

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    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.

  • Practicing Law With Parkinson's Disease

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    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.

  • 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.

  • For Lawyers, Pessimism Should Be A Job Skill, Not A Life Skill

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    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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