International
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October 17, 2024
Liberty Global Shouldn't Get $248M Tax Credit, 10th Circ. Told
Liberty Global distorted the language and statutory scheme of the U.S. tax code's foreign tax credit regulations to falsely claim $248 million in credits, the U.S. government told the Tenth Circuit on Thursday.
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October 17, 2024
India's Top Court Allows Bank To Deduct 'Broken' Interest
Interest that an Indian bank paid for government securities during what is known as the broken period between coupon payment dates is tax-deductible, the Supreme Court of India ruled, overturning a lower court.
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October 17, 2024
Financial Crime Body To Focus On High-Income Countries
An intergovernmental task force updated Thursday its criteria for placing countries on its list of those with deficiencies in their anti-money laundering and terrorist financing systems in order to focus on higher-income countries, which it said pose a higher risk than low-income countries.
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October 17, 2024
Swedish VAT Exemption Threshold Applies Cross-Border
Sweden's coming increase in the country's threshold for when businesses must begin collecting value-added tax will apply to certain companies based in other European Union member countries for their Swedish operations and to Swedish companies operating in other EU member countries, Sweden's legislature said.
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October 17, 2024
Vestager Urges EU Politicians To Push Ahead With Pillar 1
European Union competition chief Margrethe Vestager urged EU politicians Thursday to push ahead with work to finalize the Pillar One plan to redistribute taxing rights among countries.
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October 17, 2024
Polsinelli Hires McDermott Tax Counsel In DC
Polsinelli PC has hired an attorney who joined the firm's tax group as a shareholder after 12 and a half years with McDermott Will & Emery LLP.
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October 17, 2024
EU Frequent Flyer Tax Could Raise €64B, Think Tank Says
The European Union could raise an estimated €63.6 billion ($68.9 billion) in revenue by taxing frequent flyers, according to a think tank report published Thursday.
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October 16, 2024
Utah Groups Can't Scrap Corporate Transparency, US Says
A Utah federal court hasn't seen sufficient evidence to block the Corporate Transparency Act's disclosure requirements in presentations by an off-the-grid community, an online meat market and a trade group for cattle producers that have sued over the statute, the federal government said.
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October 16, 2024
Japan Signs Double-Tax Treaty With Armenia
Japan and Armenia have reached an agreement on a double-tax treaty to replace the convention Japan had with the Soviet Union, Japan's Ministry of Finance said Wednesday.
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October 16, 2024
Spain's High Court Annuls Rulings Denying R&D Deductions
Spain's Supreme Court overturned a lower court's ruling that sided with a decision from revenue officials to ignore a report from the country's science ministry when denying corporate tax deductions for research and development.
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October 16, 2024
Swedish Parliament To Consider Global Min. Tax Amendments
Sweden's government sent draft amendments regarding the country's implementation of the Organization for Economic Cooperation and Development's 15% global corporate minimum tax to its Parliament for consideration, the country's Ministry of Finance said.
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October 16, 2024
Switzerland Enshrines Ability To Tax Certain Telecommuters
Switzerland has ensured it will be able to tax employees' earned income if they telework in their country of residence for an employer based in Switzerland — under certain circumstances — starting in 2025, the country's executive body said Wednesday.
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October 16, 2024
Romania Suspends Double-Tax Treaty With Russia
Romania has completely suspended its double-tax treaty with Russia in response to Russia's cessation of parts of the treaty last year, the Romanian Ministry of Finance said Wednesday.
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October 15, 2024
Microsoft's Cost-Share Tax Arguments 'Deficient,' Mich. Says
Microsoft failed to adequately flesh out its arguments that cost-sharing agreement receipts from affiliates should be included in its Michigan apportionment formula as licenses of intellectual property, the state's tax agency argued in asking the Michigan Tax Tribunal to toss the company's case.
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October 15, 2024
Irish Tax-To-GDP Ratio Expected To Drop In 2025
Ireland's tax revenue as a share of its gross domestic product is projected to drop to 25.3% in 2025 as a result of tax measures included in the country's budget proposal, a drop of 3.1 percentage points compared with projections for this year, the country's Department of Finance said Tuesday.
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October 15, 2024
Israel-US Citizen Owes $1.1M In FBAR Penalties, US Says
A dual Israeli-American citizen who owns a Chicago pub faces more than $1 million in penalties for failing to report bank accounts that he maintained in Israel, the U.S. government told an Illinois federal court.
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October 15, 2024
New ABA Tax Chair Wants To Revamp Practice's Dry Image
The new chair of the American Bar Association Section of Taxation told Law360 she wants to boost the section's recent efforts to revamp the tax practice's image as a boring, numbers-intensive profession with limited opportunities to improve society and inspire more students to enter tax law. Here, she shares her background and goals for the tax section.
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October 15, 2024
Alvarez & Marsal Tax Brings On Restructuring Leader
Alvarez & Marsal's tax affiliate added a restructuring professional from investment bank Houlihan Lokey to serve as its head of global restructuring tax services.
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October 15, 2024
Isle Of Man Could Generate £35M Annually From Min. Tax
The Isle of Man's planned implementation of parts of the Organization for Economic Cooperation and Development's global corporate minimum tax on large multinational entities could generate as much as £35 million ($45 million) for the jurisdiction annually, its Treasury said Tuesday.
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October 15, 2024
V&E Adds Energy Tax Pro From Bracewell In Houston
Vinson & Elkins LLP has bolstered its energy transition and tax practices with a partner in Houston who came aboard from Bracewell LLP and whose background includes substantial in-house experience advising on renewable projects.
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October 15, 2024
Starmer Hints At National Insurance Hike Over Capital Gains
British Prime Minister Keir Starmer on Tuesday again refused to rule out raising employers' National Insurance, a payroll levy used to fund social programs, after downplaying claims that his government is planning to raise the capital gains tax.
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October 15, 2024
Law Firms Diverge As Anti-ESG Pushback Continues
A continuing onslaught of legislation and litigation opposing corporate environmental, social and governance actions has created a fork in the road for law firms, with some choosing to scale back efforts and others pushing ahead with their internal ESG and diversity, equity and inclusion goals.
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October 15, 2024
The 2024 Law360 Pulse Social Impact Leaders
Check out our Social Impact Leaders ranking, analysis and interactive graphics to see which firms stand out for their engagement with social responsibility and commitment to pro bono service.
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October 11, 2024
Danish Tax Agency Sniffs Out $367M In VAT Fraud
The Danish Tax Agency said it has issued collections for roughly 2.5 billion Danish kroner ($367 million) since 2018 against companies it discovered were carrying out cross-border value-added tax fraud schemes known as VAT carousels.
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October 11, 2024
France Targets Largest Cos. With Tax In Austerity Budget
The French government said it plans to implement a temporary tax targeting the country's biggest companies as part of a budget of €61.3 billion ($67 billion) of fiscal changes intended to help bring the deficit in line with European Union rules.
Expert Analysis
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After Chevron: Uniform Tax Law Interpretation Not Guaranteed
The loss of Chevron deference will significantly alter the relationship between the IRS, courts and Congress when it comes to tax law, potentially precipitating more transparent rulemaking, but also provoking greater uncertainty due to variability in judicial interpretation, say Michelle Levin and Carneil Wilson at Dentons.
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Texas Ethics Opinion Flags Hazards Of Unauthorized Practice
The Texas Professional Ethics Committee's recently issued proposed opinion finding that in-house counsel providing legal services to the company's clients constitutes the unauthorized practice of law is a valuable clarification given that a UPL violation — a misdemeanor in most states — carries high stakes, say Hilary Gerzhoy and Julienne Pasichow at HWG.
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How To Clean Up Your Generative AI-Produced Legal Drafts
As law firms increasingly rely on generative artificial intelligence tools to produce legal text, attorneys should be on guard for the overuse of cohesive devices in initial drafts, and consider a few editing pointers to clean up AI’s repetitive and choppy outputs, says Ivy Grey at WordRake.
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Industry Self-Regulation Will Shine Post-Chevron
The U.S. Supreme Court's Loper decision will shape the contours of industry self-regulation in the years to come, providing opportunities for this often-misunderstood practice, says Eric Reicin at BBB National Programs.
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3 Ways Agencies Will Keep Making Law After Chevron
The U.S. Supreme Court clearly thinks it has done something big in overturning the Chevron precedent that had given deference to agencies' statutory interpretations, but regulated parties have to consider how agencies retain significant power to shape the law and its meaning, say attorneys at K&L Gates.
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Atty Well-Being Efforts Ignore Root Causes Of The Problem
The legal industry is engaged in a critical conversation about lawyers' mental health, but current attorney well-being programs primarily focus on helping lawyers cope with the stress of excessive workloads, instead of examining whether this work culture is even fundamentally compatible with lawyer well-being, says Jonathan Baum at Avenir Guild.
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Unpacking The Circuit Split Over A Federal Atty Fee Rule
Federal circuit courts that have addressed Rule 41(d) of the Federal Rules of Civil Procedure are split as to whether attorney fees are included as part of the costs of a previously dismissed action, so practitioners aiming to recover or avoid fees should tailor arguments to the appropriate court, says Joseph Myles and Lionel Lavenue at Finnegan.
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After A Brief Hiccup, The 'Rocket Docket' Soars Back To No. 1
The Eastern District of Virginia’s precipitous 2022 fall from its storied rocket docket status appears to have been a temporary aberration, as recent statistics reveal that the court is once again back on top as the fastest federal civil trial court in the nation, says Robert Tata at Hunton.
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Recruitment Trends In Emerging Law Firm Frontiers
BigLaw firms are facing local recruitment challenges as they increasingly establish offices in cities outside of the major legal hubs, requiring them to weigh various strategies for attracting talent that present different risks and benefits, says Tom Hanlon at Buchanan Law.
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How Associates Can Build A Professional Image
As hybrid work arrangements become the norm in the legal industry, early-career attorneys must be proactive in building and maintaining a professional presence in both physical and digital settings, ensuring that their image aligns with their long-term career goals, say Lana Manganiello at Equinox Strategy Partners and Estelle Winsett at Estelle Winsett Professional Image Consulting.
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Firms Must Rethink How They Train New Lawyers In AI Age
As law firms begin to use generative artificial intelligence to complete lower-level legal tasks, they’ll need to consider new ways to train summer associates and early-career attorneys, keeping in mind the five stages of skill acquisition, says Liisa Thomas at Sheppard Mullin.
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Think Like A Lawyer: Always Be Closing
When a lawyer presents their case with the right propulsive structure throughout trial, there is little need for further argument after the close of evidence — and in fact, rehashing it all may test jurors’ patience — so attorneys should consider other strategies for closing arguments, says Luke Andrews at Poole Huffman.
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Litigation Inspiration: Attys Can Be Heroic Like Olympians
Although litigation won’t earn anyone an Olympic medal in Paris this summer, it can be worthy of the same lasting honor if attorneys exercise focused restraint — seeking both their clients’ interests and those of the court — instead of merely pursuing every advantage short of sanctionable conduct, says Bennett Rawicki at Hilgers Graben.