International

  • February 24, 2025

    Eaton's Foreign Tax Credits Rejected By Tax Court

    The U.S. Tax Court rejected foreign tax credits that Eaton Corp. had claimed on its lower-tier overseas entities' income taxes for 2007 and 2008, saying in a Monday opinion that its overseas ownership structure had disqualified the multinational power management company.

  • February 24, 2025

    Investor Settles In $2.1B Danish Tax Fraud Case

    A U.S. investor who was among those accused by Denmark's tax agency of participating in a $2.1 billion tax fraud scheme related to fraudulently claiming refunds on tax withheld from stock dividends has reached a settlement, according to New York federal court documents filed Monday.

  • February 24, 2025

    Denmark Argues Misrepresentation Led To £1.4B Tax Refunds

    Denmark's tax authority told the High Court of Justice on Monday that it would not have paid out billions in refunds to a British trader and others accused of involvement in a fraudulent trading scheme had they not submitted forms purporting to show eligibility for tax refunds.

  • February 24, 2025

    Ex-Goldman Exec Owes For Not Filing FBARs, US Says

    A former Goldman Sachs banking executive who lives in Australia owes penalties to the Internal Revenue Service for failing to report foreign bank accounts she held, the U.S. government told a D.C. federal court.

  • February 24, 2025

    NZ Reviewing Charity Business Income Tax Exemption

    New Zealand is looking for comments on its internationally unique tax structure that allows charities and not-for-profits to conduct business activities tax-free in order to raise money, asking stakeholders whether such a regime continues to be effective, the country's tax agency said Monday.

  • February 24, 2025

    Apple To Invest $500B In US Over 4 Years As Tariffs Mount

    Apple said Monday that it would invest $500 billion in the U.S. over the next four years, weeks after President Donald Trump placed a 10% tariff on goods from China, where the company sources components for its products, and threatened tariffs on semiconductors.

  • February 24, 2025

    Aussie Tax Office Agrees To Step Up Safeguards For AI

    The Australian Taxation Office said Monday that it will implement seven recommendations made by a national auditing body regarding the agency's adoption of artificial intelligence tools, including looking closer at potential data ethics risks and the overall development of the programs.

  • February 24, 2025

    High Court Won't Hear Tax Tipster's $690M Award Claim

    The U.S. Supreme Court declined on Monday to review a man's claim for a $690 million whistleblower award for undercover recordings and tips he gave the IRS that he said led to the arrests of Swiss bankers and the success of an offshore tax disclosure program.

  • February 24, 2025

    OECD Issues Consolidated Guidance On Amount B

    The OECD issued consolidated guidance Monday that it put out throughout last year for an internationally agreed-upon method to apply the arm's-length principle to pricing baseline marketing and distribution activities by multinational corporations, known as Amount B of Pillar One.

  • February 21, 2025

    Trump Says Tariffs Coming For Countries With DSTs

    President Donald Trump's administration will impose tariffs on countries with taxes that disproportionately affect American companies, such as digital services taxes, which mainly apply to tech giants, according to a memorandum released late Friday.

  • February 21, 2025

    The Tax Angle: ABA Midyear Tax Meeting

    With a lack of government officials attending the American Bar Association's midyear tax meeting, here's a peek into a reporter's notebook on a few of the week's developing tax stories.

  • February 21, 2025

    China Says Tax Deferral Boosted Foreign Reinvestment

    A tax regime exempting foreign investors from withholding taxes on certain profits generated by their China-based businesses as long as those profits are directly reinvested in projects in China led to a 15% year-over-year increase in foreign reinvestment, the country's tax administration said Friday.

  • February 21, 2025

    French 2% Minimum Wealth Tax Advances In Parliament

    French households with assets worth more than €100 million ($104.6 million) would be subject to a 2% minimum tax on their net worth annually under a top-up wealth tax proposal approved by the lower house of France's Parliament.

  • February 21, 2025

    IRS, Engineer Resolve Fight Over $5.5M In FBAR Penalties

    The U.S. government and an engineer have resolved a dispute over $5.5 million in penalties and interest regarding the nondisclosure of assets in her foreign accounts from 2009 to 2012, according to a judgment entered by a California federal court.

  • February 21, 2025

    Australia Lays Out Eligibility For Hydrogen, Mineral Credits

    The Australian Taxation Office released guidance for companies hoping to claim either of a pair of new tax incentives aimed at hydrogen and critical mineral production, including eligibility requirements and how to claim the credits.

  • February 21, 2025

    DLA Piper Tax Attorney Jumps To Vedder Price In Chicago

    Vedder Price PC has expanded its Chicago office with the addition of a skilled tax attorney who brings nearly 30 years of experience, most recently with DLA Piper.

  • February 21, 2025

    Taxation With Representation: Kirkland, V&E, Cravath, Dechert

    In this week's Taxation With Representation, Diamondback Energy buys Midland Basin assets from another oil and natural gas company, GTCR closes its second strategic growth fund, Light & Wonder Inc. buys Grover Gaming's assets, and Barings acquires Artemis Real Estate Partners.

  • February 21, 2025

    EU Tax Blacklist Needs New Criteria, Tax Pros Say

    The European Union's list of uncooperative tax jurisdictions needs new criteria to tackle the problem of corporate tax avoidance and harmful tax practices, tax campaigners claimed Friday.

  • February 21, 2025

    UK, Andorra Agree To Double-Tax Treaty

    The U.K. and Andorra have reached an agreement on a treaty to prevent double taxation that will go into effect once it is approved by both countries' legislatures, HM Revenue & Customs said Friday.

  • February 21, 2025

    UK Sticks With Inheritance Tax Changes Amid Higher Revenue

    A U.K. budget surplus, reported Friday, indicates that the Labour government shows no sign of compromising with its inheritance tax changes as tax receipts rise despite the implications for middle-class families and farmers.

  • February 20, 2025

    Biz Groups Pan Worldwide Reporting In Md. Tax Package

    Worldwide combined reporting for corporations in Maryland, along with other provisions in a legislative tax proposal, would discourage business investment in the state, business groups told a state House panel Thursday.

  • February 20, 2025

    Bradley Arant Adds Securities, Tax Expert As Partner

    Bradley Arant Boult Cummings LLP added a former Burr & Forman LLP partner to the firm's tax group and corporate and securities group in its Birmingham, Alabama, office.

  • February 20, 2025

    IRS Worker Layoff Could Hamper Enforcement, Groups Warn

    Congressional Democrats, tax and economic policy groups and an IRS workers union warned Thursday that the termination of thousands of Internal Revenue Service employees that began the same day could threaten the agency's ability to enforce tax laws and hamper taxpayer services amid tax-filing season.

  • February 20, 2025

    Guinea Fends Off Push To Enforce $22M Telecom Award

    A D.C. federal court said it lacked jurisdiction to enforce a $22 million arbitration award against the Republic of Guinea stemming from a system enabling the country to tax international telecommunications traffic, saying the nation wasn't a party to the underlying arbitration agreement.

  • February 20, 2025

    Europol Says Money-Laundering Gang Members Arrested

    European Union law enforcement officials arrested 14 individuals, primarily Russian citizens, whom they accused of laundering money for drug traffickers and other criminal groups, during raids last month in Spain and Portugal, according to a news release.

Expert Analysis

  • 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.

  • 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.

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