International

  • September 27, 2024

    Corp. AMT Rules Could Wrap In Smaller Partnerships

    Recently proposed rules on the U.S. corporate alternative minimum tax create new concerns for partnerships of various sizes that could be forced to comply with complex reporting requirements unless the government introduces carveouts, tax observers said.

  • September 27, 2024

    Ireland Seeks Input On Business Interest Tax Regime

    Ireland has asked for comments on its business interest taxation and deduction regime, as well as whether the country should introduce a commercial business purposes test for deductions, its government said Friday.

  • September 27, 2024

    Taxation With Representation: Kirkland, Skadden, Cleary

    In this week's Taxation With Representation, Blackstone and Vista Equity Partners acquire Smartsheet Inc., Macquarie Asset Management takes a stake in D.E. Shaw Renewables Investment Group, and Apogee Enterprises Inc. buys UW Interco LLC from Heartwood Partners.

  • September 27, 2024

    US Trade Group Pushes OECD On Compliance Burden

    The Organization for Economic Cooperation and Development needs to do more work on the safe harbor provisions of its Pillar Two 15% global corporate minimum tax plan — including potentially making it permanent — among other compliance burden concerns, the National Foreign Trade Council said Friday.

  • September 27, 2024

    Gov't Could Target Pension Contributions In Tax Raid

    The U.K. government could introduce a new levy on employer pension contributions as a means of plugging a £22 billion ($29.5 billion) black hole in public finances, experts said Friday.

  • September 26, 2024

    Belgian Co. Can't Keep Using Ad Space Rent-Free, ECJ Says

    The European Court of Justice on Thursday upheld a 2019 European Commission ruling that a street furniture company's owed rent for Brussels bus shelter advertising space, agreeing with the commission that allowing the company to continue using the ad displays without paying rent or taxes constituted unlawful state aid.

  • September 26, 2024

    Tribunal Halts $52.8M German Tax Collection Against Oil Cos.

    German tax authorities shouldn't collect a windfall profits tax totaling at least €47.2 million ($52.8 million) from two oil refineries before the dispute has been litigated, a tribunal of the International Centre for Settlement of Investment Disputes said.

  • September 26, 2024

    Montreal Exchange Is A Qualified Exchange, IRS Says

    The Montreal Exchange is a qualified board or exchange for purposes of mark-to-market contracts under Internal Revenue Code Section 1256(g)(7)(C), the Internal Revenue Service said Thursday. 

  • September 26, 2024

    Amazon Reports Paying £932M In UK Taxes In 2023

    Amazon said Thursday that it paid a total of £932 million ($1.25 billion) in U.K. taxes last year, which the company said puts it among the 10 largest taxpayers in the country.

  • September 26, 2024

    Tariff Tax Base Too Small To Replace Income Tax, Report Says

    Higher tariffs can't replace income tax revenue, as former President Donald Trump has suggested, since U.S. imports total $3 trillion annually while incomes top $20 trillion, but they would lower incomes by raising prices for U.S. consumers, a think tank reported Thursday.

  • September 26, 2024

    Irish Dividend Exemption Too Restrictive, Big 4 Say

    The Big Four accounting firms raised concerns about wording in Ireland's planned tax exemption for foreign-sourced dividends, claiming in comments released Thursday that it would be overly restrictive to require dividends to come solely out of an offshore affiliate's profits.

  • September 26, 2024

    Harris' And Trump's Tax Plans Each Add To Deficit, Study Says

    The U.S. federal deficit would grow by at least $2 trillion over the next decade from the tax policy plans of both major parties' candidates, former President Donald Trump and Vice President Kamala Harris, researchers said Thursday.

  • September 26, 2024

    UK Cos. Claimed Nearly £1.5B In Patent Box Relief In 2022-23

    While there was a slight dip in the number of U.K. companies that elected to use the country's patent box tax regime in the 2022-23 tax year compared with the prior year, the estimated value of relief claimed jumped to nearly £1.47 billion ($1.97 billion) compared with around £1.33 billion, HM Revenue & Customs said Thursday.

  • September 26, 2024

    UK R&D Tax Credit Claims Down, But Total Relief Up £100M

    While there was an over 20% dip in research and development tax credit claims in the U.K. in the 2022-23 tax year, the total relief claimed rose to £7.5 billion ($10.1 billion), a £100 million increase, HM Revenue & Customs said Thursday.

  • September 26, 2024

    UK Corp. Tax Receipts Up 10% To £93.3B, HMRC Says

    The U.K. generated £93.3 billion ($125 billion) in corporate tax receipts in the 2023-24 tax year, a 10% increase over the prior year, HM Revenue & Customs said Thursday, pointing mainly to the increase in the country's corporation tax rate to 25% as the reason behind the bump.

  • September 26, 2024

    ECJ Backs Strong Protection For Lawyer-Client Discussions

    Confidentiality of lawyer-client communications has enhanced protection under European Union law, including in cross-border tax disclosures, the European Court of Justice ruled Thursday.

  • September 26, 2024

    OECD Publishes Streamlined Amount B Model Agreement

    The Organization for Economic Cooperation and Development published a model agreement Thursday for a simplified and streamlined approach to the Amount B portion of Pillar One, a transfer pricing plan for certain baseline marketing and distribution activities.

  • September 25, 2024

    IBM Urges Justices To Review NY Tax On Foreign Royalties

    New York's system for taxing royalty payments would be unconstitutional if every other jurisdiction adopted it, violating an internal consistency test reaffirmed by a 2015 precedent, IBM told the U.S. Supreme Court in asking it to review and overturn New York's high court ruling that allowed the tax regime.

  • September 25, 2024

    Boosting Indirect Tax Revenues Can Tackle Debt, OECD Says

    A number of countries should look to eliminate distortive tax expenses as well as increase their revenue from certain taxes to help manage debt sustainability and make their economies more supportive of growth, the Organization for Economic Cooperation and Development said Wednesday.

  • September 25, 2024

    Expect More R&D Guidance Before Regs, IRS Atty Says

    The Internal Revenue Service plans to release more guidance governing the tax treatment of research and development expenses before it formally issues proposed regulations that implement the 2017 federal tax law's changes to the incentive, an agency attorney said Wednesday.

  • September 25, 2024

    EU States Must Unify Divergent Biz Rules, Majority Says

    The European Union must double down on unifying its divergent rules for businesses in a policy proposal next year because the bloc's main competitive advantage is its single market, almost three-quarters of EU countries told the bloc's executive arm.

  • September 25, 2024

    Basis-Shifting Regs May Add Accounting Fixes, IRS Atty Says

    The Internal Revenue Service may include in upcoming proposed regulations a solution for partnership basis-shifting for taxpayers that want to adjust accounting methods so prior transactions can be compliant with economic substance laws, an agency attorney said Wednesday.

  • September 25, 2024

    Wyden Calls On 2025 Tax Bill To Include Partnership Reform

    Lawmakers should consider next year how to revise partnership tax laws to better collect on large businesses' income without harming smaller entities as Congress debates over how to address expiring tax provisions, Senate Finance Committee Chairman Ron Wyden said Wednesday.

  • September 25, 2024

    Australia Floats Updates To Amended Tax Pro Conduct Code

    After repeated pushback against changes to Australia's tax agent code of conduct, the country's Treasury proposed two further amendments Wednesday that aim to address complaints regarding corrections of false or misleading statements and disclosures of information to clients.

  • September 25, 2024

    Hong Kong, Turkey Reach Double-Tax Agreement

    Hong Kong and Turkey agreed to a treaty to prevent double taxation, which would take effect after approval by both jurisdictions' legislatures, Hong Kong's Inland Revenue Department said.

Expert Analysis

  • 6 Practice Pointers For Pro Bono Immigration Practice

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    An attorney taking on their first pro bono immigration matter may find the law and procedures beguiling, but understanding key deadlines, the significance of individual immigration judges' rules and specialized aspects of the practice can help avoid common missteps, says Steven Malm at Haynes Boone.

  • Lessons From Country Singer's Personal Service Saga

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    Recent reports that country singer Luke Combs won a judgment against a Florida woman who didn’t receive notice of the counterfeit suit against her should serve as a reminder for attorneys on best practices for effectuating service by electronic means, say attorneys at Jenner & Block.

  • 7 E-Discovery Predictions For 2024 And Beyond

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    The legal and technical issues of e-discovery now affect virtually every lawsuit, and in the year to come, practitioners can expect practices and policies to evolve in a number of ways, from the expanded use of relevancy redactions to mandated information security provisions in protective orders, say attorneys at Littler.

  • 5 Litigation Funding Trends To Note In 2024

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    Over the next year and beyond, litigation funding will continue to evolve in ways that affect attorneys and the larger litigation landscape, from the growth of a secondary market for funded claims, to rising interest rates restricting the availability of capital, says Jeffery Lula at GLS Capital.

  • 4 Legal Ethics Considerations For The New Year

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    As attorneys and clients reset for a new year, now is a good time to take a step back and review some core ethical issues that attorneys should keep front of mind in 2024, including approaching generative artificial intelligence with caution and care, and avoiding pitfalls in outside counsel guidelines, say attorneys at HWG.

  • What The Law Firm Of The Future Will Look Like

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    As the legal landscape shifts, it’s become increasingly clear that the BigLaw business model must adapt in four key ways to remain viable, from fostering workplace flexibility to embracing technology, say Kevin Henderson and Eric Pacifici at SMB Law Group.

  • 4 PR Pointers When Your Case Is In The News

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    Media coverage of new lawsuits exploded last year, demonstrating why defense attorneys should devise a public relations plan that complements their legal strategy, incorporating several objectives to balance ethical obligations and advocacy, say Nathan Burchfiel at Pinkston and Ryan June at Castañeda + Heidelman.

  • Unpacking The Proposed Production Tax Credit Regulations

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    Recently proposed tax regulations for claiming the U.S. clean-energy manufacturers' production credit under Internal Revenue Code Section 45X are less stringent than many had feared but fail to define a fundamental eligibility requirement, say Casey August and Jared Sanders at Morgan Lewis.

  • 10 Considerations For Litigating A New York Tax Case

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    While some of New York’s recently adopted corporate tax regulations are likely to face legal challenges, aggrieved taxpayers should answer certain questions before deciding to embark on the tax litigation process, say Cyavash Ahmadi and Jeffrey Friedman at Eversheds Sutherland.

  • Law Firm Strategies For Successfully Navigating 2024 Trends

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    Though law firms face the dual challenge of external and internal pressures as they enter 2024, firms willing to pivot will be able to stand out by adapting to stakeholder needs and reimagining their infrastructure, says Shireen Hilal at Maior Consultants.

  • Attorneys' Busiest Times Can Be Business Opportunities

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    Attorneys who resolve to grow their revenue and client base in 2024 should be careful not to abandon their goals when they get too busy with client work, because these periods of zero bandwidth can actually be a catalyst for future growth, says Amy Drysdale at Alchemy Consulting.

  • How Attorneys Can Be More Efficient This Holiday Season

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    Attorneys should consider a few key tips to speed up their work during the holidays so they can join the festivities — from streamlining the document review process to creating similar folder structures, says Bennett Rawicki at Hilgers Graben.

  • How Clients May Use AI To Monitor Attorneys

    Excerpt from Practical Guidance
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    Artificial intelligence tools will increasingly enable clients to monitor and evaluate their counsel’s activities, so attorneys must clearly define the terms of engagement and likewise take advantage of the efficiencies offered by AI, says Ronald Levine at Herrick Feinstein.

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