International

  • August 26, 2024

    Kyocera's Gross-Up Doesn't Grant $143M Tax Break, US Says

    Electronics maker Kyocera cannot be allowed to take a $143 million tax deduction for distributions received under a 2017 tax law based on a separate statute's gross-up for paid foreign tax credits, the government told a South Carolina federal court.

  • August 26, 2024

    New Zealand Considers OECD Crypto Reporting Framework

    New Zealand would implement the Organization for Economic Cooperation and Development's framework for automatically exchanging financial information regarding crypto-assets under a proposal the country's revenue minister sent to its Legislature on Monday.

  • August 26, 2024

    Canada Planning 100% Surtax On Chinese EVs, 25% On Steel

    Canada plans to implement a 100% surtax on imported Chinese electric vehicles and a 25% surtax on Chinese steel and aluminum as part of a package intended to protect Canadian industry from unfair competition, the country's Department of Finance said Monday.

  • August 23, 2024

    Chamber Backs Doctor In Tax Court Economic Substance Suit

    The U.S. Chamber of Commerce lent its support to an eye doctor and his wife's U.S. Tax Court case disputing accuracy-related penalties that the Internal Revenue Service plans to impose on their microcaptive insurance arrangements for lacking economic substance.

  • August 23, 2024

    IRS Spinoff Guidance Sparks Worries About Short-Term Debt

    Companies that intend to give creditors equity tied to a spinoff transaction won't get early tax-free approval if the exchange involves recently acquired debt under IRS guidance that practitioners say draws an arbitrary line without accounting for ordinary business operations.

  • August 23, 2024

    Alvarez & Marsal Adds Transfer Pricing Expert From EY

    A former EY partner joined Alvarez & Marsal LLC to serve as managing director of its transfer pricing line of services in its New York office, the firm announced.

  • August 23, 2024

    45% Of US Biz Income Abroad In Tax Havens, Data Shows

    U.S. multinational corporations booked about 45% of their $1.33 trillion in net foreign income in 2022 in low-tax jurisdictions where around 1.7% of their employees are located, according to an analysis of data released Friday by the Bureau of Economic Analysis.

  • August 23, 2024

    German Official Backs Anti-Abuse Tax Rules Roll-Back Review

    A German Federal Ministry of Finance official agreed with tax experts' proposal to review the anti-abuse provisions of international tax law in order to potentially roll them back, especially with the global corporate minimum tax going into force across the European Union.

  • August 23, 2024

    Taxation With Representation: Latham, Wachtell, Paul Weiss

    In this week's Taxation With Representation, Arch Resources merges with Consol Energy in a deal worth $5.2 billion, Advanced Micro Devices agrees to purchase ZT Systems for $4.9 billion, and Japanese tobacco company JT Group inks a deal to buy Vector Group for $2.4 billion.

  • August 23, 2024

    HMRC Can Be Liable For Damage To Biz Shut Over £7.4M Debt

    The tax authority cannot lift a court order that requires it to repay a payroll business damages for losses suffered after it was put into provisional liquidation, as a court found on Friday that it had failed to pursue that action for law enforcement purposes.

  • August 22, 2024

    Switzerland Expects 3.2% Tax Receipt Increase In 2025

    Switzerland expects to generate 85.7 billion Swiss francs ($100.6 billion) in tax receipts in 2025, an increase of 3.2% over the 2024 budget, with the biggest growth projected to come from personal income taxes, the country's Federal Finance Administration said Thursday.

  • August 22, 2024

    Kenya's Justices May Ax Part Of Tax Act That Set Off Unrest

    The Supreme Court of Kenya agreed to stay a lower court's ruling declaring unconstitutional the government's entire 2023 tax package, which sparked deadly nationwide protests, but it looks likely to scrap at least part of the law next month, attorneys told Law360 on Thursday.

  • August 22, 2024

    Australian Legislators Advance Enactment Of Global Min. Tax

    Australia would enact the Organization for Economic Cooperation and Development's 15% global corporate minimum tax on large multinational entities, known as Pillar Two, under three bills passed Thursday by the country's House of Representatives.

  • August 22, 2024

    EU Decision Keeps Tax Relief For UK Investment Schemes

    The European Commission will allow U.K. government-backed programs that encourage private investment in small companies to continue offering favorable tax terms for investors, according to a decision published Thursday.

  • August 22, 2024

    Ryanair Threatens Service Cuts Over German Tax Increase

    Irish discount airline Ryanair said it will cut 10% of its German capacity next summer if the country doesn't reverse a recent 24% increase in its aviation tax, calling on Germany to ultimately abolish the tax altogether.

  • August 22, 2024

    Over 3M UK Pensioners To Be Dragged Into Higher Tax Rates

    Government data shows 3.1 million U.K. pensioners will be dragged into paying higher taxes in the next four years due to the freeze on income thresholds, financial firm Quilter PLC said Thursday.

  • August 21, 2024

    Ariz. Man Should Pay Full $2.7M FBAR Bill, Gov't Says

    An Arizona man who failed to report his foreign bank accounts in Switzerland owes approximately $2.7 million in recalculated penalties and interest to the Internal Revenue Service, the U.S. told an Arizona federal court.

  • August 21, 2024

    UK Tax Collection Rises 5% To £829B

    HM Revenue & Customs said Wednesday that the U.K. raised over £829 billion ($1.09 trillion) in taxes in fiscal year 2023-2024, up over 5% from the previous year.

  • August 21, 2024

    9th Circ. Upholds FBAR Penalty, Imposes Contested Interest

    A woman who operates a New Zealand winery must pay $238,000 in penalties and an extra $105,000 in interest and fees for failing to report her New Zealand financial accounts to the U.S. government, the Ninth Circuit ruled Wednesday.

  • August 21, 2024

    3 Questions Raised By Harris' Support For 28% Corp. Tax Rate

    Vice President Kamala Harris has proposed increasing the corporate tax rate to 28% to boost revenue if she's elected president, but the proposed hike raises questions about changes to the corporate tax base, the future of the OECD's global tax deal and the potential impact on workers.

  • August 21, 2024

    Pros Tell IRS To Ease Off Foreign Gift Reporting Penalties

    The Internal Revenue Service should take a more lenient approach when considering penalty abatements for certain individuals who fail to report large foreign gifts under proposed disclosure regulations, practitioners told the agency Wednesday.

  • August 21, 2024

    New Zealand Seeks Feedback On Future Of Tax System

    New Zealand's revenue agency is looking for feedback on plans for a potential broad restructuring of the country's tax system in order to address coming financial pressures, including possibly altering its income and consumption tax regimes, it said Wednesday.

  • August 21, 2024

    Swiss Council Approves Tax Treaty With Jordan

    Switzerland's Federal Council approved a treaty Wednesday to avoid double taxation with Jordan that it says largely follows the Organization for Economic Cooperation and Development's model convention for such agreements.

  • August 21, 2024

    Swiss Extend Tax Exemptions For 'Too Big To Fail' Instruments

    Switzerland's Federal Council decided Wednesday to extend temporary withholding tax exemptions on interest for what it calls too-big-to-fail instruments for banks, such as bail-in or write-off bonds.

  • August 21, 2024

    Germany Opens Consultation On Min. Tax Reporting Changes

    Germany's Federal Ministry of Finance is seeking feedback on a proposal to incorporate updated guidance from the Organization for Economic Cooperation and Development regarding reporting requirements associated with the global corporate minimum tax.

Expert Analysis

  • A Year-End Look At Florida's Capital Investment Tax Credit

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    Notwithstanding the Walt Disney Co.’s feud with Gov. Ron DeSantis this year, Florida's capital investment tax credit will continue to make the state a favored destination for large corporations, particularly in light of the new federal alternative minimum tax and the Pillar Two top-up tax, says Alan Lederman at Gunster.

  • Understanding Discovery Obligations In Era Of Generative AI

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    Attorneys and businesses must adapt to the unique discovery challenges presented by generative artificial intelligence, such as chatbot content and prompts, while upholding the principles of fairness, transparency and compliance with legal obligations in federal civil litigation, say attorneys at King & Spalding.

  • The Case For Post-Bar Clerk Training Programs At Law Firms

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    In today's competitive legal hiring market, an intentionally designed training program for law school graduates awaiting bar admission can be an effective way of creating a pipeline of qualified candidates, says Brent Daub at Gilson Daub.

  • AI Can Help Lawyers Overcome The Programming Barrier

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    Legal professionals without programming expertise can use generative artificial intelligence to harness the power of automation and other technology solutions to streamline their work, without the steep learning curve traditionally associated with coding, says George Zalepa at Greenberg Traurig.

  • Preparing Law Students For A New, AI-Assisted Legal World

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    As artificial intelligence rapidly transforms the legal landscape, law schools must integrate technology and curricula that address AI’s innate challenges — from ethics to data security — to help students stay ahead of the curve, say Daniel Garrie at Law & Forensics, Ryan Abbott at JAMS and Karen Silverman at Cantellus Group.

  • General Counsel Need Data Literacy To Keep Up With AI

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    With the rise of accessible and powerful generative artificial intelligence solutions, it is imperative for general counsel to understand the use and application of data for myriad important activities, from evaluating the e-discovery process to monitoring compliance analytics and more, says Colin Levy at Malbek.

  • Navigating Discovery Of Generative AI Information

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    As generative artificial intelligence tools become increasingly ubiquitous, companies must make sure to preserve generative AI data when there is reasonable expectation of litigation, and to include transcripts in litigation hold notices, as they may be relevant to discovery requests, say Nick Peterson and Corey Hauser at Wiley.

  • Finding Focus: Strategies For Attorneys With ADHD

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    Given the prevalence of ADHD among attorneys, it is imperative that the legal community gain a better understanding of how ADHD affects well-being, and that resources and strategies exist for attorneys with this disability to manage their symptoms and achieve success, say Casey Dixon at Dixon Life Coaching and Krista Larson at Stinson.

  • Attorneys, Law Schools Must Adapt To New Era Of Evidence

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    Technological advancements mean more direct evidence is being created than ever before, and attorneys as well as law schools must modify their methods to account for new challenges in how this evidence is collected and used to try cases, says Reuben Guttman at Guttman Buschner.

  • 1st Tax Easement Convictions Will Likely Embolden DOJ, IRS

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    After recent convictions in the first criminal tax fraud trial over allegedly abusive syndicated conservation easements, the IRS and U.S. Department of Justice will likely pursue other promoters for similar alleged conspiracies — though one acquittal may help attorneys better evaluate their clients' exposure, say Bill Curtis and Lauren DeSantis-Then at Polsinelli.

  • Tips For Litigating Against Pro Se Parties In Complex Disputes

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    Litigating against self-represented parties in complex cases can pose unique challenges for attorneys, but for the most part, it requires the same skills that are useful in other cases — from documenting everything to understanding one’s ethical duties, says Bryan Ketroser at Alto Litigation.

  • Anticipating Intensified Partnership Enforcement From IRS

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    The Internal Revenue Service's decadeslong difficulties with partnership audits led to the recent announcement of a clear, well-funded, focused initiative, and businesses operating in the partnership form will feel the impact, with definite changes ahead, says Sharon Katz-Pearlman at Greenberg Traurig.

  • Pro Bono Work Is Powerful Self-Help For Attorneys

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    Oct. 22-28 is Pro Bono Week, serving as a useful reminder that offering free legal help to the public can help attorneys expand their legal toolbox, forge community relationships and create human connections, despite the challenges of this kind of work, says Orlando Lopez at Culhane Meadows.

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