International
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September 06, 2024
Federal Tax Policies To Watch In The Rest Of The Year
As Congress returns to Washington, D.C., after the August recess, proposals including disaster tax relief and an agreement to provide tax treaty-like benefits to Taiwanese residents could be readied to be included in year-end legislation. Here, Law360 examines federal tax policies to watch during the last four months of 2024.
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September 06, 2024
FDII Covers Overseas Services For US Gov't, Memo Says
Government contractors that provide services to U.S. operations overseas are allowed to claim the deduction for foreign-derived intangible income, the IRS said in one of two internal memos released Friday that address foreign income issues.
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September 06, 2024
Broaden Tax Bases For Cleaner Energy Transition, EU Says
The impact on government revenues from the transition to cleaner energy, including diminishing fossil fuel tax receipts and increased spending on subsidies supporting green technology, necessitates that countries develop broader tax bases, the European Commission said.
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September 06, 2024
4 Key Complications 3 Years After Pillar 2
Three years ago, countries around the world outlined an agreed-upon minimum corporate tax system in an eight-page document that couldn't have foreseen the full scope of complications that later emerged during implementation, including frictions with existing tax laws. Here, Law360 looks at four key issues that countries and multinational corporations are grappling with as Pillar Two turns three.
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September 06, 2024
China Complains To WTO About Canada EV Surtaxes
China is looking for the World Trade Organization to step in to address proposed Canadian surtaxes on imported Chinese electric vehicles, steel and aluminum, taxes that a spokesperson for China's Ministry of Commerce said Friday violate the organization's rules.
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September 06, 2024
Taxation With Representation: Debevoise, Bennett, Orrick
In this week's Taxation With Representation, Verizon reaches a deal to absorb Frontier in a deal worth $20 billion, First Majestic agrees to buy Gatos Silver for $970 million, and Epam Systems inks a $630 million purchase of Neoris.
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September 06, 2024
Vialto Partners Member Joins Baker McKenzie As Partner
Baker McKenzie has hired a tax partner in Washington, D.C., from Vialto Partners, a business consulting firm, the firm announced Thursday.
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September 06, 2024
EU Should Align Disclosure Standards, Industry Group Says
The European Union should align its forthcoming public tax reporting rules with the same systems in use under the Organization for Economic Cooperation and Development's non-public reporting system, the American Chamber of Commerce in the EU said.
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September 05, 2024
Unconstitutionality Of Transparency Act Clear, 11th Circ. Told
A small business group and one of its members have told the Eleventh Circuit that an Alabama federal judge correctly ruled that the Corporate Transparency Act is unconstitutional, so there was no need for them to demonstrate that the law fails to pass constitutional muster.
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September 05, 2024
Liberty Global Urges 10th Circ. To Grant $248M Tax Credit
The U.S. Tax Court improperly applied an Internal Revenue Code provision to some of the $2.8 billion gain from Liberty Global's sale of a Japanese entity, the telecommunications company said in urging the Tenth Circuit to overturn the resulting rejection of a $248 million tax credit.
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September 05, 2024
Holland & Knight Appoints Former Perkins Coie Tax Partner
Holland & Knight LLP appointed a partner to its Portland, Oregon, office who previously served as a partner in energy tax law for Perkins Coie LLP, the firm announced.
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September 05, 2024
Sen. Finance Panel To Hold Hearing On Tax Policy, Avoidance
The Senate Finance Committee will hold a hearing Sept. 12 covering the 2025 tax policy debate and tax avoidance strategies, it announced Thursday.
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September 05, 2024
Broad, Low-Rate DST May Placate US, Ex-OECD Chief Tells EU
The European Union might be able to break an impasse with the U.S. in negotiations on taxing the digital economy by proposing a digital services tax with a wide base and a low rate, former OECD tax chief Pascal Saint-Amans told Paolo Gentiloni, the bloc's economics commissioner.
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September 05, 2024
UK Extends Startup Investment Tax Incentives Through 2035
Two U.K. tax incentives that encourage private investment in small companies in order to boost innovation and otherwise stimulate economic growth have been extended for 10 years, HM Treasury said.
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September 05, 2024
Tax Pros Want Aussie PM To Halt Code Of Conduct Changes
Six groups representing Australian tax professionals and accountants called on the country's prime minister to step in to stop an "unfair" bill updating the code of conduct for tax agent services if discussions with the country's Treasury don't produce what they say are needed changes.
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September 04, 2024
IRS' Economic Substance Authority Has Limits, Tax Court Told
The U.S. Tax Court and other federal courts have the authority to conduct an initial analysis of a transaction in cases where the Internal Revenue Service is challenging the economic substance of the transaction, a manufacturers advocacy group said Wednesday in an amicus brief.
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September 04, 2024
New Zealand Looking To Nearly Triple Its Tourist Levy
New Zealand's government is planning to increase a levy on tourists to NZ$100 ($62) per visit, nearly tripling the current rate, according to a joint statement from the country's conservation and tourism ministries.
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September 04, 2024
Irish Tax Surplus Too Reliant On Few Cos., Watchdog Says
It's dangerous for the Irish government to fund long-term plans with corporate tax windfalls pouring into its coffers for over a decade, as three foreign-owned multinational corporations are providing a growing share, risking volatility in an otherwise healthy economy, a parliamentary watchdog said.
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September 04, 2024
Singapore's Annual Corporate Tax Revenue Climbs 26%
Singapore collected SG$80.3 billion ($61.6 billion) in tax revenue in fiscal year 2023-24, a 17% increase over the prior year, thanks in large part to a 25.6% increase in corporate income tax receipts, pushing that total to SG$29 billion, the country's revenue agency said Wednesday.
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September 04, 2024
Swiss To Impose Second Portion Of Pillar 2 Starting In 2025
Switzerland will implement the income inclusion rule portion of the OECD's Pillar Two standards to fight tax base erosion and profit shifting starting in 2025, its Federal Council said Wednesday, complementing its establishment of the 15% global minimum corporate income tax this year.
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September 03, 2024
11th Circ. Trims $12.6M FBAR Fine In 8th Amendment Split
Some of the $12.6 million in penalties the IRS on imposed a man for willfully failing to report foreign bank accounts were in violation of the Eighth Amendment's bar on excessive fines, the Eleventh Circuit ruled, creating an apparent circuit split.
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September 03, 2024
Bahrain Adopting Global Minimum Tax In 2025
Multinational corporations making more than €750 million ($828 million) annually operating in Bahrain will be subject to the OECD's 15% global minimum corporate income tax starting in 2025, the country's tax agency said.
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September 03, 2024
UN Tax Rule On Payments Best For Many Gov'ts, Group Says
Developing countries should seek to add the United Nations' version of a minimum tax rule on payments to their bilateral tax treaties and to adopt corresponding laws domestically while approaching the OECD's more restrictive multilateral version with caution, an advocacy group said Tuesday.
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September 03, 2024
Ex-Defense Contractor Arrested In $350M Tax Evasion Case
A former defense contractor who, with his wife, is facing a 30-count indictment alleging they were involved in a decades-long scheme to defraud the U.S. government and avoid taxes on more than $350 million in income was arrested Tuesday.
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September 03, 2024
NZ Ratifies Slovakia Tax Agreement, Amends Austria Treaty
New Zealand government ratified a new treaty to avoid double taxation with Slovakia as well as amendments to a previous treaty with Austria, the country's tax agency said.
Expert Analysis
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Neb. Justices Should Weigh IRC Terms In Dividend Tax Case
Nebraska’s highest court, which will hear oral arguments in Precision CastParts v. Department of Revenue on April 1, should recognize that the Internal Revenue Code provides key clues to defining “dividends received or deemed to be received,” and therefore limits Nebraska’s tax on foreign-sourced corporate income, says Joseph Schmidt at Ryan.
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Judicial Independence Is Imperative This Election Year
As the next election nears, the judges involved in the upcoming trials against former President Donald Trump increasingly face political pressures and threats of violence — revealing the urgent need to safeguard judicial independence and uphold the rule of law, says Benes Aldana at the National Judicial College.
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Spartan Arbitration Tactics Against Well-Funded Opponents
Like the ancient Spartans who held off a numerically superior Persian army at the Battle of Thermopylae, trial attorneys and clients faced with arbitration against an opponent with a bigger war chest can take a strategic approach to create a pass to victory, say Kostas Katsiris and Benjamin Argyle at Venable.
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What Recent Study Shows About AI's Promise For Legal Tasks
Amid both skepticism and excitement about the promise of generative artificial intelligence in legal contexts, the first randomized controlled trial studying its impact on basic lawyering tasks shows mixed but promising results, and underscores the need for attorneys to proactively engage with AI, says Daniel Schwarcz at University of Minnesota Law School.
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How FinCEN Proposal Expands RE Transaction Obligations
Against a regulatory backdrop foreshadowing anti-money laundering efforts in the real estate sector, the Financial Crimes Enforcement Network's proposed rule significantly expands reporting requirements for certain nonfinanced residential real estate transfers and necessitates careful review, say attorneys at Fried Frank.
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Litigation Inspiration: A Source Of Untapped Fulfillment
As increasing numbers of attorneys struggle with stress and mental health issues, business litigators can find protection against burnout by remembering their important role in society — because fulfillment in one’s work isn’t just reserved for public interest lawyers, say Bennett Rawicki and Peter Bigelow at Hilgers Graben.
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Unpacking FinCEN's Proposed Real Estate Transaction Rule
Phil Jelsma and Ulrick Matsunaga at Crosbie Gliner take a close look at the Financial Crimes Enforcement Network's recently proposed rulemaking — which mandates new disclosures for professionals involved in all-cash real estate deals — and discuss best next steps for the broad range of businesses that could be affected.
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Think Like A Lawyer: Forget Everything You Know About IRAC
The mode of legal reasoning most students learn in law school, often called “Issue, Rule, Application, Conclusion,” or IRAC, erroneously frames analysis as a separate, discrete step, resulting in disorganized briefs and untold obfuscation — but the fix is pretty simple, says Luke Andrews at Poole Huffman.
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How New EU Tax And Transfer Pricing Rules May Affect M&A
Companies involved in mergers and acquisitions may need to adjust fiscal due diligence procedures to ensure they consider potential far-reaching effects of newly implemented transfer pricing measures, such as newly implemented global minimum tax and European Union anti-tax avoidance directives and proposals, says Patrick Tijhuis at BDO.
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How Firms Can Ensure Associate Gender Parity Lasts
Among associates, women now outnumber men for the first time, but progress toward gender equality at the top of the legal profession remains glacially slow, and firms must implement time-tested solutions to ensure associates’ gender parity lasts throughout their careers, say Kelly Culhane and Nicole Joseph at Culhane Meadows.
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7 Common Myths About Lateral Partner Moves
As lateral recruiting remains a key factor for law firm growth, partners considering a lateral move should be aware of a few commonly held myths — some of which contain a kernel of truth, and some of which are flat out wrong, says Dave Maurer at Major Lindsey.
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6 Pointers For Attys To Build Trust, Credibility On Social Media
In an era of information overload, attorneys can use social media strategically — from making infographics to leveraging targeted advertising — to cut through the noise and establish a reputation among current and potential clients, says Marly Broudie at SocialEyes Communications.
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US-Chile Tax Treaty May Encourage Cross-Border Investment
Provisions in the recently effective U.S.-Chile bilateral income tax treaty should encourage business between the two countries, as they reduce U.S. withholding tax on investment income for Chilean taxpayers, exempt certain U.S. taxpayers from Chilean capital gains tax, and clarify U.S. foreign tax credit rules, say attorneys at Kramer Levin.