International
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September 05, 2024
Tax Pros Want Aussie PM To Halt Code Of Conduct Changes
Six groups representing Australian tax professionals and accountants called on the country's prime minister to step in to stop an "unfair" bill updating the code of conduct for tax agent services if discussions with the country's Treasury don't produce what they say are needed changes.
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September 04, 2024
IRS' Economic Substance Authority Has Limits, Tax Court Told
The U.S. Tax Court and other federal courts have the authority to conduct an initial analysis of a transaction in cases where the Internal Revenue Service is challenging the economic substance of the transaction, a manufacturers advocacy group said Wednesday in an amicus brief.
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September 04, 2024
New Zealand Looking To Nearly Triple Its Tourist Levy
New Zealand's government is planning to increase a levy on tourists to NZ$100 ($62) per visit, nearly tripling the current rate, according to a joint statement from the country's conservation and tourism ministries.
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September 04, 2024
Irish Tax Surplus Too Reliant On Few Cos., Watchdog Says
It's dangerous for the Irish government to fund long-term plans with corporate tax windfalls pouring into its coffers for over a decade, as three foreign-owned multinational corporations are providing a growing share, risking volatility in an otherwise healthy economy, a parliamentary watchdog said.
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September 04, 2024
Singapore's Annual Corporate Tax Revenue Climbs 26%
Singapore collected SG$80.3 billion ($61.6 billion) in tax revenue in fiscal year 2023-24, a 17% increase over the prior year, thanks in large part to a 25.6% increase in corporate income tax receipts, pushing that total to SG$29 billion, the country's revenue agency said Wednesday.
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September 04, 2024
Swiss To Impose Second Portion Of Pillar 2 Starting In 2025
Switzerland will implement the income inclusion rule portion of the OECD's Pillar Two standards to fight tax base erosion and profit shifting starting in 2025, its Federal Council said Wednesday, complementing its establishment of the 15% global minimum corporate income tax this year.
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September 03, 2024
11th Circ. Trims $12.6M FBAR Fine In 8th Amendment Split
Some of the $12.6 million in penalties the IRS on imposed a man for willfully failing to report foreign bank accounts were in violation of the Eighth Amendment's bar on excessive fines, the Eleventh Circuit ruled, creating an apparent circuit split.
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September 03, 2024
Bahrain Adopting Global Minimum Tax In 2025
Multinational corporations making more than €750 million ($828 million) annually operating in Bahrain will be subject to the OECD's 15% global minimum corporate income tax starting in 2025, the country's tax agency said.
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September 03, 2024
UN Tax Rule On Payments Best For Many Gov'ts, Group Says
Developing countries should seek to add the United Nations' version of a minimum tax rule on payments to their bilateral tax treaties and to adopt corresponding laws domestically while approaching the OECD's more restrictive multilateral version with caution, an advocacy group said Tuesday.
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September 03, 2024
Ex-Defense Contractor Arrested In $350M Tax Evasion Case
A former defense contractor who, with his wife, is facing a 30-count indictment alleging they were involved in a decades-long scheme to defraud the U.S. government and avoid taxes on more than $350 million in income was arrested Tuesday.
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September 03, 2024
NZ Ratifies Slovakia Tax Agreement, Amends Austria Treaty
New Zealand government ratified a new treaty to avoid double taxation with Slovakia as well as amendments to a previous treaty with Austria, the country's tax agency said.
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September 03, 2024
Non-EU Cos. Need Clarity On Public Tax Reporting, Firms Say
The European Union should clarify how multinational corporations headquartered outside the bloc need to format tax data they report under new public disclosure rules, global accounting firms said.
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September 03, 2024
Higher UK Windfall Tax Will Cut Revenue, Says Industry Group
The U.K. government's plan to raise the energy windfall tax in November may cost HM Treasury around £12 billion ($15.7 billion) in tax revenue, according to an industry group.
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September 03, 2024
Norway Seeks Input On Beneficial Ownership Register Access
Norway's Ministry of Finance is seeking comments on a proposal laying out rules regarding access to the country's beneficial ownership register, the ministry said Tuesday.
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September 03, 2024
IRS Issues More Edits For Foreign Currency Accounting Regs
The Internal Revenue Service issued further corrections Tuesday to proposed rules that would adjust the timing for when companies can use certain accounting methods for gains or losses that arise from foreign currency transactions.
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August 30, 2024
Alvarez & Marsal Appoints Tax Experts As Managing Directors
Alvarez & Marsal Tax LLC appointed tax experts from Anderson and Deloitte as its new managing directors, the firm announced.
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August 30, 2024
Danish Gov't Pledges No Ponzi Analogies At $2.1B Tax Trial
The Danish tax authority won't compare pension funds, investors and attorneys it has accused of defrauding Denmark in a $2.1 billion tax refund scheme to a Ponzi scheme or infamous perpetrator Bernie Madoff, it said Friday in New York federal court.
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August 30, 2024
US Seeks Trade Talks In Dispute Over Canada's Digital Tax
The Office of the U.S. Trade Representative announced Friday that it has requested dispute settlement discussions with Canada regarding the country's recently enacted digital services tax, which the USTR claims discriminates against U.S. companies.
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August 30, 2024
Whistleblower Seeks 2nd Bid At $690M Claim In DC Circ.
A whistleblower denied up to $690 million, or 30%, of the $2.3 billion collected in an Internal Revenue Service offshore voluntary disclosure program asked for a D.C. Circuit panel to rehear his case Friday, saying its original opinion included numerous mistakes and misunderstandings.
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August 30, 2024
UK's Labour Gov't Urged To Raise Capital Gains Tax
The Labour government is facing calls to raise the capital gains tax despite financial firms advising investors to sell off their assets or even leave the United Kingdom over the possible tax hike.
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August 30, 2024
IRS Corrects Proposed Rules To Address Pillar 2 Losses
The Internal Revenue Service issued corrections Friday to proposed rules that outline when foreign taxes under the Pillar Two international minimum tax agreement could trigger long-standing U.S. rules that aim to prevent companies from what is known as double-dipping the same economic loss.
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August 30, 2024
Taxation With Representation: Kirkland, Paul Weiss, Squire
In this week's Taxation With Representation, Oneok reaches two agreements with energy infrastructure companies worth a total $5.9 billion, McKesson inks a $2.49 billion deal for a cancer center, and First Busey and CrossFirst Bankshares agree to a $917 million merger.
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August 30, 2024
Neb. Justices Affirm Nix Of Berkshire Unit's Tax Deduction Bid
A Nebraska tax deduction for certain dividends doesn't apply to income repatriated under the 2017 federal tax overhaul, the state Supreme Court affirmed Friday in rejecting arguments from a Berkshire Hathaway entity that the state's tax system excluded the foreign earnings from tax.
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August 29, 2024
Tax Court Rejects Bid To Change Ruling Post-Chevron
The U.S. Supreme Court's recent overturning of the Chevron standard of judicial deference to agencies when interpreting statutes does not justify reconsidering a Cayman Islands partnership's tax liability, the U.S. Tax Court ruled.
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August 29, 2024
4th Circ. Won't Revive Whistleblower's Credit Suisse Tax Suit
The Fourth Circuit upheld the dismissal of a former Credit Suisse employee's whistleblower case that alleged the Swiss bank continued to help clients evade taxes after it made a related plea deal with the U.S., saying a 2023 U.S. Supreme Court decision on the False Claims Act could not save the case.
Expert Analysis
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US-Chile Tax Treaty May Encourage Cross-Border Investment
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.
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A Post-Mortem Analysis Of Stroock's Demise
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.
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SG's Office Is Case Study To Help Close Legal Gender Gap
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.
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Reimagining Law Firm Culture To Break The Cycle Of Burnout
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.
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Cayman Islands Off AML Risk Lists, Signaling Robust Controls
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.
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The Legal Industry Needs A Cybersecurity Paradigm Shift
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.
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As Promised, IRS Is Coming For Crypto Tax Evaders
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.
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5 Reasons Associates Shouldn't Take A Job Just For Money
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.
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The Pop Culture Docket: Judge Djerassi On Super Bowl 52
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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Employee Experience Strategy Can Boost Law Firm Success
Amid continuing business uncertainty, law firms should consider adopting a holistic employee experience strategy — prioritizing consistency, targeting signature moments and leveraging measurement tools — to maximize productivity and profitability, says Haley Revel at Calibrate Consulting.
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6 Practice Pointers For Pro Bono Immigration Practice
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.
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Lessons From Country Singer's Personal Service Saga
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.
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7 E-Discovery Predictions For 2024 And Beyond
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.