International

  • August 02, 2024

    Top UK Court To Hear HMRC Car Park Tax Dispute With NHS

    HM Revenue and Customs has been granted permission by Britain's highest court to challenge a ruling that a National Health Service trust qualified for value-added tax exemption for hospital car parking, a decision that could affect appeals brought by NHS entities.

  • August 01, 2024

    Divided Tax Court Says Treaty Bars Collections Hearing

    A divided U.S. Tax Court ruled Thursday that it lacked authority to review an Internal Revenue Service decision preventing a woman from challenging a federal tax lien the agency issued on behalf of the Canadian government to secure her tax debt to that country.

  • August 01, 2024

    Coca-Cola, IRS Enter $2.7B Tax Bill In Transfer Pricing Dispute

    Coca-Cola and the IRS submitted tax liability calculations totaling $2.73 billion to the U.S. Tax Court, reflecting the latest step in the company's long-running transfer pricing dispute over the agency's reallocation of the company's foreign affiliate income.

  • August 01, 2024

    EU Seeking Input On Electronic Country-By-Country Reporting

    The European Commission is looking for feedback on draft regulations creating a common template and electronic format for country-by-country reporting forms that large multinational corporations operating in the European Union will be required to use to disclose their corporate taxes, the EU's executive arm said Thursday.

  • August 01, 2024

    Airbnb's $1.3B Bill From IRS Overvalues IP, Tax Court Told

    Airbnb is challenging a $1.3 billion tax bill tied to income the IRS allocated from overseas, telling the U.S. Tax Court the agency overvalued intellectual property the home-rental giant licensed to its Irish affiliate before going public.

  • August 01, 2024

    Australia Seeking Feedback On Nonresident Trust Guidance

    The Australian Taxation Office is soliciting input on draft guidelines for compliance with the country's income tax obligations in cases where property of a nonresident trust is paid to or applied for the benefit of a resident beneficiary.

  • August 01, 2024

    3rd Circ. Affirms Nix Of Discovery Ask On GM In Brazil Case

    A Delaware federal court didn't abuse its discretion by declining to begin discovery on General Motors to aid ongoing litigation in Brazil for a group that is entitled to receive dozens of car dealerships' tax credits from the early 1990s, the Third Circuit found.

  • August 01, 2024

    15 Arrested In Albanian Ring Involving Money Laundering

    A "prominent money launderer" was among 15 members of what was called a high-profile Albanian organized crime group arrested by authorities under suspicion of crimes including contract killings and money laundering using cryptocurrency transactions, Europol said Thursday.

  • August 01, 2024

    Australia Slows Tax Pro Conduct Code Update After Blowback

    The Australian government is delaying the start of its newly passed changes to the country's code of conduct for tax agent services, which were supposed to enter into force this month, following pushback from industry groups, a minister said Thursday.

  • August 01, 2024

    Taxpayers Find Belgian Pillar 2 Request Sudden, Intrusive

    Belgian demands for detailed information that must be supplied within a short deadline are troubling taxpayers within the scope of the global minimum corporate tax, who said the country's quest for information is more challenging than that imposed by other governments.

  • August 01, 2024

    UK Capital Gains Tax Liabilities Decline, HMRC Says

    Capital gains tax liability in the U.K. declined in the 2022-2023 tax year, HM Revenue & Customs said in a news release Thursday.

  • July 31, 2024

    Treasury's New 'Killer B' Rules May Revive Controversies

    Recent U.S. Treasury Department regulations centered on contentious 2011 guidance aimed at so-called Killer B transactions have revived long-standing questions about how much authority rule writers have to target what they perceive as corporate tax avoidance in these maneuvers.

  • July 31, 2024

    'Tax Avoidance' Fuels Global Reporting Pushback, Pro Says

    A lobbying effort from multinational corporations to dissuade states from adopting mandatory worldwide combined reporting aims to keep billions of dollars in profits that were shifted into tax-friendly jurisdictions beyond the reach of tax administrators, a retired researcher from a progressive think tank said Wednesday.

  • July 31, 2024

    Cos. Insist Chevron Ruling Doesn't Change Deduction Claims

    A medical device company and a food services firm that are each challenging Internal Revenue Service denials of dividend deduction claims told the U.S. Tax Court that the recent U.S. Supreme Court decision overturning Chevron deference doesn't change the validity of their arguments.

  • July 31, 2024

    SEC Asked For Public Tax Reporting By Group With $2.3T

    The U.S. Securities and Exchange Commission was asked Wednesday to begin a rulemaking procedure to require public country-by-country reporting of tax by nearly 90 investment funds, labor unions, activists and others with combined assets over $2.3 trillion.

  • July 31, 2024

    Americans Overseas Launch Residence Taxation Lobby Group

    An advocacy group representing U.S. citizens living abroad announced it has officially registered as a lobbyist to continue to push Congress to pass residence-based taxation laws for the benefit of individuals comparable to those for corporations.

  • July 31, 2024

    Senators Ask Treasury To Limit Biofuel Tax Credit Eligibility

    The U.S. Treasury Department shouldn't grant biofuel production tax credits to companies that use foreign-sourced feedstocks, a coalition of Republican and Democratic senators said in a letter published Wednesday.

  • July 31, 2024

    DMH Stallard Adds Tax Atty To London Practice

    DMH Stallard LLP hired a tax attorney for its London office who spent more than a decade at HM Revenue & Customs working on compliance and policy, according to a news release.

  • July 31, 2024

    Large UK Cos. Expect Major Pillar 2 Administrative Burden

    While businesses largely reported they expect the U.K.'s implementation of the OECD's corporate global minimum tax to have little to no impact on the amount of tax they pay, they also are concerned about the law's administrative burden, HM Revenue & Customs said.

  • July 31, 2024

    Australia Seeking Members For Pillar 2 Working Group

    The Australian Taxation Office said it is seeking members to join a working group focused on the country's implementation of the Organization for Economic Cooperation and Development's Pillar Two global minimum tax.

  • July 31, 2024

    EU Seeks Feedback On Effectiveness Of Anti-Avoidance Law

    The European Commission said Wednesday that it is looking for feedback on how the European Union's anti-tax avoidance directive has fared since going into force in 2020, in particular concerning the bloc-wide implementation of the OECD's global minimum corporate tax standards.

  • July 31, 2024

    French Politician Wants VAT Cut For Repairs To Churches

    A French politician is asking the European Commission to consider expanding the scope of rate reductions for value-added taxes to include the renovation of historic monuments, including churches, according to a letter released Wednesday.

  • July 30, 2024

    IRS Spinoff Guidance Raises Practical Concerns, NY Attys Say

    Recent IRS guidance narrowing the corporate spinoff transactions that revenue officials will approve as tax-free ahead of time doesn't adequately consider the practical and commercial factors involved in these transactions, the New York State Bar Association's Tax Section said Tuesday.

  • July 30, 2024

    Israeli Man Seeks To Avoid Discovery In $3.6M FBAR Case

    A federal court should not order the Israeli founder of a pet toy company to show cause for defying its discovery orders in the U.S. government's $3.6 million case over his failure to report foreign bank accounts because he is ending his defense, his attorneys said Tuesday.

  • July 30, 2024

    Kyocera Chides Gov't Attack On Jurisdiction In $7M Tax Case

    The government's attempt to defeat a South Carolina federal court's jurisdiction is improper because it relies on a roughly $44 million assessment lodged months after electronics maker Kyocera filed an amended complaint for a $7 million federal tax refund, according to the company.

Expert Analysis

  • A Post-Mortem Analysis Of Stroock's Demise

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    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.

  • SG's Office Is Case Study To Help Close Legal Gender Gap

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    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.

  • Reimagining Law Firm Culture To Break The Cycle Of Burnout

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    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.

  • Cayman Islands Off AML Risk Lists, Signaling Robust Controls

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    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.

  • The Legal Industry Needs A Cybersecurity Paradigm Shift

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    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.

  • As Promised, IRS Is Coming For Crypto Tax Evaders

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    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.

  • 5 Reasons Associates Shouldn't Take A Job Just For Money

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    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.

  • The Pop Culture Docket: Judge Djerassi On Super Bowl 52

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    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.

  • Employee Experience Strategy Can Boost Law Firm Success

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    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.

  • 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.

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