International

  • October 29, 2024

    Croatia, Australia Reach Double Tax Treaty Agreement

    Croatia and Australia have agreed on a treaty to avoid double taxation that will take effect when passed by the respective legislatures, the Croatian Ministry of Finance said.

  • October 29, 2024

    States Should Cede Profit-Shifting Fight To OECD, Atty Says

    States should shy away from using mandatory worldwide combined reporting to address profit shifting and instead allow the Organization for Economic Cooperation and Development to police tax avoidance from multinational corporations, a business trade group attorney said Tuesday.

  • October 29, 2024

    Switzerland Amends Double Tax Treaty With Kuwait

    Switzerland said Tuesday it has ratified changes to its double taxation treaty with Kuwait that are due to take effect early next year.

  • October 29, 2024

    US, Taiwan To Begin Talks On Double-Tax Agreement

    The U.S. and Taiwan announced Tuesday that they will begin a first round of negotiations to craft a double-tax avoidance agreement that would provide certain treaty-like benefits.

  • October 28, 2024

    Russia Says High Court Case May Help Nix $5B Award Suit

    Russia has told a D.C. federal court that a case recently accepted for review by the U.S. Supreme Court may provide it a path to argue that the court lacks jurisdiction to decide a case brought against the country by a Yukos Oil Co. unit.

  • October 28, 2024

    Latin America, Caribbean Must Up Tobacco Taxes, OECD Says

    Latin American and Caribbean countries must increase their tobacco excise tax levels, among other changes, to reduce the overall affordability of tobacco products to drive people to quit using them, the Organization for Economic Cooperation and Development said Monday.

  • October 28, 2024

    UK Construction Co. Due £3.2M In R&D Credits, Refunds

    A construction contractor is entitled to tax credits and refunds totaling over £3.2 million ($4.2 million) after the U.K.'s First-tier Tribunal ruled that its expenditures for research and development were not subsidized or contracted out by another party.

  • October 28, 2024

    European Commission Backs Simplified Minimum Tax Filing

    Multinational corporations could file returns for the 15% global minimum tax with a single country in the European Union that they would share with the others only where necessary under a proposal approved Monday by the bloc's executive branch, according to officials.

  • October 28, 2024

    Labour Budget Expected To Target Taxes At Biz, Investors

    The U.K. government is set to unveil its budget statement Wednesday after months of hinting at higher taxes, and experts say businesses and investors are bracing to bear the brunt of the possible tax changes, such as through increases to capital gains and payroll taxes.

  • October 28, 2024

    Chile Provides Guidance For Voluntary Disclosure Program

    Chile's tax agency provided guidance Monday for taxpayers interested in voluntarily disclosing their previously undeclared foreign assets in order to take advantage of a temporarily available tax rate.

  • October 28, 2024

    IRS Extends Relief For FATCA Filings Without ID Numbers

    Foreign financial institutions that report information on U.S. account holders to the Internal Revenue Service without including the taxpayer identification numbers associated with those accounts won't be flagged for noncompliance for the next three years, the agency said Monday.

  • October 28, 2024

    Wise Boss Hit With FCA Fine For Not Disclosing Tax Penalty

    The finance regulator said on Monday that it has fined the chief executive of a money transfer company £350,000 ($454,500) for his failure to tell the watchdog he had been penalized by HM Revenues and Customs for not paying his taxes.

  • October 28, 2024

    US Expatriations Tick Up In 3rd Quarter, IRS Says

    The number of people who expatriated from the U.S. rose during the third quarter of the year compared with the previous quarter, the Internal Revenue Service said Monday.

  • October 25, 2024

    German Drug Co. Due £21.5M VAT Refund, UK Tribunal Finds

    A German pharmaceutical provider is entitled to a refund of almost £21.5 million ($27.9 million) for the value-added tax it paid on the rebated portion of products supplied to the U.K.'s National Health Service, the British First-tier Tribunal ruled.

  • October 25, 2024

    Lebanon, Angola, Others Added To Financial Crime Watch List

    An intergovernmental task force on financial crimes added Lebanon, Angola, Algeria and the Ivory Coast to a watch list of countries with weak protections against money laundering and financing for armed groups, the group said Friday.

  • October 25, 2024

    Argentina Formally Shutters, Replaces Tax Agency

    Argentina's president formally dissolved the country's tax agency, the Federal Public Revenue Administration, and established a new agency, following through on an announcement two days earlier to end what he characterized as an oversize entity.

  • October 25, 2024

    Authorities Bust €113M VAT Fraud Ring Between Italy, China

    A sting carried out Friday by the European Public Prosecutor's Office busted a crime ring involving the import of clothing and accessories from China to Italy that hid the goods' origins in order to evade €113 million ($122 million) in value-added taxes, the EPPO said.

  • October 25, 2024

    Taxation With Representation: Davis Polk, Skadden, Kirkland

    In this week's Taxation With Representation, Atlantic Union Bankshares Corp. absorbs Sandy Spring Bancorp, Sophos and Secureworks merge, Wendel Group takes a stake in Monroe Capital LLC, and Acuity Brands Inc. buys QSC LLC.

  • October 25, 2024

    MVP: Wachtell's Tijana J. Dvornic

    Wachtell Lipton Rosen & Katz's Tijana J. Dvornic led the firm's tax team in representing Lumen Technologies in the largest liability management transaction outside of bankruptcy protections, including addressing over $15 billion of existing debt, earning her a spot as one of the 2024 Law360 Tax MVPs.

  • October 25, 2024

    Germany's Expected Tax Take For 5 Years Drops €58B

    Germany expects to raise €58.2 billion ($63 billion) less in revenue through 2028 than what was forecast in May, according to the country's finance minister, who said that the government allowing employers to pay tax-free bonuses caused uncertainties regarding income tax collections.

  • October 24, 2024

    IRS To End Automatic Foreign Gift Reporting Penalty

    Internal Revenue Service Commissioner Danny Werfel told the UCLA Tax Controversy Conference audience on Thursday that the agency will no longer automatically assess penalties for the late reporting of large foreign gifts, with the announcement eliciting applause from the audience of several hundred tax attorneys and tax professionals.

  • October 24, 2024

    IRS Forming Transfer Pricing Team To Aid Real-Time Audits

    The Internal Revenue Service is establishing a dedicated team to tackle transfer pricing issues that arise in real-time audits of companies participating in its compliance assurance process program, which should allow those issues to be handled more efficiently, an agency official said Thursday.

  • October 24, 2024

    Nigeria Frees Binance Exec Detained Over Money Laundering

    Nigeria's government released a top executive at cryptocurrency exchange Binance whom the government had been holding liable for money laundering charges against the company, the U.S. government and the exchange's CEO said Thursday.

  • October 24, 2024

    Wyden's Pharma Probe Could Build Case For Int'l Tax Reforms

    Senate Finance Committee Chairman Ron Wyden's investigation into the tax planning of major U.S. pharmaceutical companies could help fuel an effort to revamp U.S. international tax laws next year when Congress addresses expiring provisions of the Tax Cuts and Jobs Act.

  • October 24, 2024

    Politics Blocking Amount B Consensus, OECD Tells G20

    Continued delays of the Organization for Economic Cooperation and Development's transfer pricing plan for certain baseline marketing and distribution activities known as Amount B of Pillar One are due to "primarily political" issues as opposed to technical problems, the organization told the Group of 20 on Thursday.

Expert Analysis

  • 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.

  • Neb. Justices Should Weigh IRC Terms In Dividend Tax Case

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    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.

  • Judicial Independence Is Imperative This Election Year

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    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.

  • Spartan Arbitration Tactics Against Well-Funded Opponents

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    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.

  • What Recent Study Shows About AI's Promise For Legal Tasks

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    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.

  • How FinCEN Proposal Expands RE Transaction Obligations

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    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.

  • Litigation Inspiration: A Source Of Untapped Fulfillment

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    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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