International
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October 18, 2024
Ending Nonresident Tax Breaks Could Harm UK, Report Says
The U.K.'s plans to abolish nondomicile tax status for high-net-worth individuals could reduce the country's economic size by nearly £6.5 billion ($8 billion) by 2035, according to recent research.
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October 18, 2024
Bahamas' Parliament To Consider Global Min. Tax Bill
Qualifying businesses in the Bahamas would be subject to one portion of the OECD's 15% global corporate minimum income tax on large multinational entities making over €750 million ($815 million) annually, under legislation sent to the country's Parliament.
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October 18, 2024
IRS OKs Rules On Withholding For Pension Payments
The Internal Revenue Service released final rules Friday covering certain retirement plans' obligation to withhold income tax when they make payments or distributions to taxpayers outside the U.S. starting in 2026.
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October 18, 2024
Taxation With Representation: Baker, Simpson, Ropes
In this week's Taxation With Representation, Lundbeck inks a $2.6 billion cash deal for Longboard, Silver Lake agrees to buy Zuora for $1.7 billion, and PPG and American Industrial Partners reach a $550 million deal.
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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.
Expert Analysis
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Attorneys' Busiest Times Can Be Business Opportunities
Attorneys who resolve to grow their revenue and client base in 2024 should be careful not to abandon their goals when they get too busy with client work, because these periods of zero bandwidth can actually be a catalyst for future growth, says Amy Drysdale at Alchemy Consulting.
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How Attorneys Can Be More Efficient This Holiday Season
Attorneys should consider a few key tips to speed up their work during the holidays so they can join the festivities — from streamlining the document review process to creating similar folder structures, says Bennett Rawicki at Hilgers Graben.
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How Clients May Use AI To Monitor Attorneys
Excerpt from Practical Guidance
Artificial intelligence tools will increasingly enable clients to monitor and evaluate their counsel’s activities, so attorneys must clearly define the terms of engagement and likewise take advantage of the efficiencies offered by AI, says Ronald Levine at Herrick Feinstein.
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The Pop Culture Docket: Judge D'Emic On Moby Grape
The 1968 Moby Grape song "Murder in My Heart for the Judge" tells the tale of a fictional defendant treated with scorn by the judge, illustrating how much the legal system has evolved in the past 50 years, largely due to problem-solving courts and the principles of procedural justice, says Kings County Supreme Court Administrative Judge Matthew D'Emic.
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Breaking Down High Court's New Code Of Conduct
The U.S. Supreme Court recently adopted its first-ever code of conduct, and counsel will need to work closely with clients in navigating its provisions, from gift-giving to recusal bids, say Phillip Gordon and Mateo Forero at Holtzman Vogel.
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Legal Profession Gender Parity Requires Equal Parental Leave
To truly foster equity in the legal profession and to promote attorney retention, workplaces need to better support all parents, regardless of gender — starting by offering equal and robust parental leave to both birthing and non-birthing parents, says Ali Spindler at Irwin Fritchie.
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A Year-End Look At Florida's Capital Investment Tax Credit
Notwithstanding the Walt Disney Co.’s feud with Gov. Ron DeSantis this year, Florida's capital investment tax credit will continue to make the state a favored destination for large corporations, particularly in light of the new federal alternative minimum tax and the Pillar Two top-up tax, says Alan Lederman at Gunster.
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Understanding Discovery Obligations In Era Of Generative AI
Excerpt from Practical Guidance
Attorneys and businesses must adapt to the unique discovery challenges presented by generative artificial intelligence, such as chatbot content and prompts, while upholding the principles of fairness, transparency and compliance with legal obligations in federal civil litigation, say attorneys at King & Spalding.
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The Case For Post-Bar Clerk Training Programs At Law Firms
In today's competitive legal hiring market, an intentionally designed training program for law school graduates awaiting bar admission can be an effective way of creating a pipeline of qualified candidates, says Brent Daub at Gilson Daub.
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AI Can Help Lawyers Overcome The Programming Barrier
Legal professionals without programming expertise can use generative artificial intelligence to harness the power of automation and other technology solutions to streamline their work, without the steep learning curve traditionally associated with coding, says George Zalepa at Greenberg Traurig.
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Preparing Law Students For A New, AI-Assisted Legal World
As artificial intelligence rapidly transforms the legal landscape, law schools must integrate technology and curricula that address AI’s innate challenges — from ethics to data security — to help students stay ahead of the curve, say Daniel Garrie at Law & Forensics, Ryan Abbott at JAMS and Karen Silverman at Cantellus Group.
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General Counsel Need Data Literacy To Keep Up With AI
With the rise of accessible and powerful generative artificial intelligence solutions, it is imperative for general counsel to understand the use and application of data for myriad important activities, from evaluating the e-discovery process to monitoring compliance analytics and more, says Colin Levy at Malbek.
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Navigating Discovery Of Generative AI Information
As generative artificial intelligence tools become increasingly ubiquitous, companies must make sure to preserve generative AI data when there is reasonable expectation of litigation, and to include transcripts in litigation hold notices, as they may be relevant to discovery requests, say Nick Peterson and Corey Hauser at Wiley.