International

  • June 01, 2024

    Blockbuster Summer: 10 Big Issues Justices Still Must Decide

    As the calendar flips over to June, the U.S. Supreme Court still has heaps of cases to decide on issues ranging from trademark registration rules to judicial deference and presidential immunity. Here, Law360 looks at 10 of the most important topics the court has yet to decide.

  • May 31, 2024

    3M Tells 8th Circ. IRS Used Invalid Regs For $24M Allocation

    Multinational conglomerate 3M reiterated Friday its bid for the Eighth Circuit to reverse a U.S. Tax Court decision allowing the IRS to allocate nearly $24 million from the company's Brazilian affiliate, arguing the agency's adjustment relied on substantively invalid regulations.

  • May 31, 2024

    IRS Guidance Narrows Spinoffs Available For Preapproval

    Recent IRS guidance limiting the types of spinoff transactions that revenue officials will approve as tax-free ahead of time leaves practitioners and corporations to determine whether to pursue certain intercompany reorganizations without the agency's blessing.

  • May 31, 2024

    Ex-UBS Exec Owes $4.7M In FBAR Penalties, Court Told

    A former CEO of Swiss bank UBS' North American group faces a $4.7 million tax bill that the U.S. claims is due because he did not report his foreign bank accounts or assets, according to a suit filed in Connecticut federal court.

  • May 31, 2024

    US, Bulgaria Sign Country-By-Country Reporting Agreement

    The U.S. and Bulgaria signed an agreement Friday on the automatic exchange of country-by-country reports between the nations, Bulgaria's Ministry of Finance said.

  • May 31, 2024

    Latin American Tax Transparency Generates €2.1B In 5 Years

    Tax transparency measures such as exchanges of financial information in Latin American countries have generated nearly €2.1 billion ($2.3 billion) in additional revenue over the past five years, according to an Organization for Economic Cooperation and Development report.

  • May 31, 2024

    Calif. Man Owes 6 Years Of FBAR Penalties, IRS Tells Court

    A Californian has failed to pay foreign bank account reporting penalties he was assessed that were tied to a business he owed in Mexico for six years, the Internal Revenue Service told a federal court.

  • May 31, 2024

    Taxation With Representation: Cravath, Cleary, Fried Frank

    In this week's Taxation With Representation, T-Mobile buys United States Cellular Corp.'s wireless operations, Energy Transfer plans to buy WTG Midstream, ConocoPhillips acquires Marathon Oil, and Goldman Sachs Alternatives raises over $20 billion for its direct lending strategy.

  • May 31, 2024

    Denmark's New VAT System Cuts Errors By 30%, Agency Says

    A new Danish value-added tax reporting system that digitally cross-checks with data for European Union trade has reduced errors by about 30%, Denmark's tax agency said Friday.

  • May 31, 2024

    EU Eyes Permanent End To Vanuatu Visa Waiver

    The European Commission said Friday that it wants to permanently end visa-free access for nationals of Vanuatu to the European Union because the EU says the island nation hasn't addressed risks in its investor citizenship programs.

  • May 30, 2024

    EU Court Rejects Appeal Over Spanish Port Tax Breaks

    The European Union's Court of Justice on Thursday upheld a lower court ruling that corporate tax exemptions Spain extended to seaports were illegal state aid, brushing aside arguments that a more thorough economic analysis was warranted to prove the tax breaks bestowed an unfair advantage.

  • May 30, 2024

    Aussie State's Parliament Urges Taxing Consulting Cos.

    Large companies that provide consulting services to the New South Wales government should be required to pay taxes on their company earnings along with payroll taxes on partnership earnings, according to a report from the Australian state's Parliament.

  • May 30, 2024

    Qatar Signs Double-Tax Agreements With Saudi Arabia, UAE

    Qatar signed two agreements Thursday to prevent double taxation and tax evasion, one with Saudi Arabia and the other with the United Arab Emirates.

  • May 30, 2024

    Later Pillar 1 Due Date Set For June As Tax Talks Wrap Up

    Diplomats agreed this week to finalize a treaty for reallocating some of large companies' tax payments and setting standards to simplify some transfer pricing in lower-income countries by June 30 after having missed a March deadline, according to a statement published Thursday by the OECD.

  • May 30, 2024

    Ex-KPMG Manager Joins Davis+Gilbert As Tax Partner

    A former managing director at KPMG has joined New York law firm Davis+Gilbert LLP as a tax partner in its corporate and transactions practice, Davis+Gilbert announced.

  • May 30, 2024

    Tax Pros Agree With HMRC's Mandatory Agent Reporting Plan

    Two groups representing tax professionals in the U.K. have agreed with a proposed rule requiring practitioners to register with HM Revenue & Customs while also supporting a secondary rule that would require membership with a professional body.

  • May 30, 2024

    Russian Gas Ex-CFO Says $44M FBAR Penalty Is Excessive

    The former chief financial officer of a Russian gas company who was sentenced to seven years in prison for hiding money in Swiss banks told a Florida federal court that the $44 million in foreign account reporting penalties the government is seeking is illegally high.

  • May 30, 2024

    Panama Papers Leak Led To $283M In Swedish Tax Revenue

    The Swedish Tax Agency said Thursday it has corrected the tax assessments of roughly 100 people and companies connected to the so-called Panama Papers leak, capturing roughly 3 billion Swedish kronor ($283 million) in added tax revenue.

  • May 30, 2024

    Legal Advice On Corp. Setups Protected, ECJ Adviser Says

    A law firm's legal advice, even that concerning the setting up of a corporate investment structure, is within the scope of legal professional privilege guaranteed by European Union law, an adviser to the EU's highest court said Thursday.

  • May 30, 2024

    EU's Top Court Rules Spanish Regional Energy Taxes Illegal

    European Union energy tax law forbids Spanish regions to set their own rates for excise duty on energy, the EU's top court said Thursday, finding that possible exemptions did not apply in the Spanish case.

  • May 30, 2024

    Freeze On UK Tax Thresholds Set To Expire in 2028, Hunt Says

    Chancellor Jeremy Hunt said on Thursday that the freeze on income tax thresholds will continue until 2028, despite promises by the Conservative government to reduce the overall taxation burden in the future.

  • May 30, 2024

    Italian Rules On Internet Companies Unlawful, ECJ Finds

    Amazon, Google, Airbnb and other internet companies have won their fight against a law requiring them to provide Italian authorities with information about their operations as the European Union's highest court ruled Thursday that the obligation breaches of the bloc's rules.

  • May 29, 2024

    Irish Court Denies $19.2M Tax Payment To Australia

    The Australian Taxation Office lost a bid to have a now-liquidated Australian investment company repay a AU$29 million ($19.2 million) tax debt after an Irish court determined the payment should instead go to a lender.

  • May 29, 2024

    Colombian Court Affirms Fossil Fuel Tax Break Must Stay

    The Constitutional Court of Colombia affirmed its decision to strike down a law denying fossil fuel companies the ability to offset corporate income tax liabilities with deductions for royalty payments despite a severe impact to public finances, the country's president said.

  • May 29, 2024

    Baker McKenzie Grows Tax Practice With Ex-KPMG Adviser

    Baker McKenzie announced the hiring of an experienced Chicago-based tax adviser as a principal who most recently spent sixteen and a half years at Big Four accounting firm KPMG.

Expert Analysis

  • 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.

  • Requiring Leave To File Amicus Briefs Is A Bad Idea

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    A proposal to amend the Federal Rules of Appellate Procedure that would require parties to get court permission before filing federal amicus briefs would eliminate the long-standing practice of consent filing and thereby make the process less open and democratic, says Lawrence Ebner at the Atlantic Legal Foundation and DRI Center.

  • 4 Ways To Motivate Junior Attorneys To Bring Their Best

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    As Gen Z and younger millennial attorneys increasingly express dissatisfaction with their work and head for the exits, the lawyers who manage them must understand and attend to their needs and priorities to boost engagement and increase retention, says Stacey Schwartz at Katten.

  • Former Minn. Chief Justice Instructs On Writing Better Briefs

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    Former Minnesota Supreme Court Chief Justice Lorie Gildea, now at Greenberg Traurig, offers strategies on writing more effective appellate briefs from her time on the bench.

  • Stay Interviews Are Key To Retaining Legal Talent

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    Even as the economy shifts and layoffs continue, law firms still want to retain their top attorneys, and so-called stay interviews — informal conversations with employees to identify potential issues before they lead to turnover — can be a crucial tool for improving retention and morale, say Tina Cohen Nicol and Kate Reder Sheikh at Major Lindsey.

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