International
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August 16, 2024
Kyocera Says It Doesn't Need Records For R&D Credits
Multinational electronics maker Kyocera said Friday that it wasn't required to keep any specific paperwork to back up its claim to research tax credits, contrary to the U.S. government's claims, according to a filing in South Carolina federal court.
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August 16, 2024
UK Dependency Considering Global Minimum Tax Bills
Jersey is considering draft legislation that would implement the Organization for Economic Cooperation and Development's 15% minimum tax on multinational entities making over €750 million ($828 million) annually, in line with a declaration from it and other U.K. crown dependencies to do so starting next year.
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August 16, 2024
Democratic Gov't Control Could Bolster US' Pillar 2 Plans
Vice President Kamala Harris and congressional Democrats would likely double down on plans to align the U.S. tax code with the global minimum tax designed by the Organization for Economic Cooperation and Development if they win total control of the federal government in the November elections.
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August 16, 2024
UN Votes For Global Services As First Priority Under Tax Pact
The United Nations voted Friday to make taxation of cross-border services the most prioritized topic for a legally binding agreement to be finalized by late 2027 alongside the organization's framework convention on international tax cooperation.
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August 16, 2024
IRS To Let Private Cos. Into Real-Time Biz Audit Program
The Internal Revenue Service is opening its compliance assurance process real-time audit program to privately held C corporations, including foreign-owned ones, for 2025, the agency announced.
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August 16, 2024
Taxation With Representation: Cleary, Kirkland, Skadden
In this week's Taxation with Representation, Mars Inc. sets a 2024 record with its $36 billion acquisition of Kellanova, Carlyle inks a $3.8 billion purchase with Baxter International Inc., and Performance Food Group Co. agrees to a $2.1 billion cash deal with Cheney Bros. Inc.
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August 15, 2024
Doctor Wants Contempt Fine Dropped In Foreign Asset Case
A doctor who incurred $1.1 million in liabilities for failing to report his foreign bank accounts is asking a Michigan federal court to waive his $20,000 civil contempt fine because the court restricted his only financial assets to paying the liabilities.
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August 15, 2024
Tax Pros Navigate Chaos, Rewards In Climate Law's 2nd Year
Energy tax attorneys have been knee-deep in project finance deals for the past year since the Inflation Reduction Act of 2022 triggered a flurry of clean energy investments, but the work, they say, has been fulfilling as part of broader efforts to save the environment.
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August 15, 2024
Taxes Could Be Key To Cutting Crypto Emissions, IMF Says
The growing environmental impact of crypto-asset mining and related data centers could be mitigated with tax measures aimed directly at such facilities, the International Monetary Fund said Thursday.
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August 15, 2024
Germany Seeks Input On Tightened Transfer Pricing Rules
Germany is poised to make multinational corporations responsible for showing the economic necessity of intra-group, cross-border debt relationships when they deduct expenses for financing with borrowed capital, according to a consultation by the federal government.
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August 15, 2024
Finland To Have EU's 2nd-Highest VAT Rate Starting Sept. 1
Finland's general value-added tax rate will jump to 25.5% from 24% starting Sept. 1, the country's tax agency said Thursday, putting it behind only Hungary for the highest VAT rate in the European Union.
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August 15, 2024
Aussie Senate Economics Committee OKs 15% Min. Tax Bill
The Australian Senate's Economics Legislation Committee said it supports the passage of a three-bill package that would implement the OECD's 15% global corporate minimum tax on large multinational entities, sending it to the entire Senate for approval.
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August 15, 2024
UK Plastic Packaging Tax Revenue Dipped By 6%
The U.K. collected £268 million ($344 million) from its tax on certain plastic packaging manufactured in or imported into the country in the 2023-2024 fiscal year, down 6% from the £285 million the year prior, HM Revenue & Customs said Thursday.
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August 14, 2024
PwC Owes $11M For Tax Errors, Real Estate Group Says
PwC should pay £8.9 million ($11.4 million) in damages to a real estate group for miscalculating its tax liabilities and mispricing its properties, which prompted several additional assessments and penalties, according to a claim in a London court.
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August 14, 2024
Baker McKenzie Adds Tax Expert To Monterrey Office
Baker McKenzie has added a partner from Turanzas Bravo & Ambrosi to its Monterrey, Mexico, office who brings more than 15 years of experience practicing international trade law with a focus on taxation and customs-related litigation.
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August 14, 2024
Kenya Tax Court Finds Chinese Firm Dodged $7.8M VAT
A Kenyan tax court affirmed an assessment that found a China-based firm used a series of shell companies to dodge over 1 billion Kenyan shillings ($7.8 million) in value-added tax payments, the Kenya Revenue Authority said Wednesday.
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August 14, 2024
Swiss Seeking Input On Delays Of Crypto-Asset Info Exchange
Switzerland's executive body, the Federal Council, is looking for public input on when it should begin automatically exchanging financial information regarding crypto-assets with countries with which it already has set up general automatic exchange of information agreements, its finance ministry said.
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August 14, 2024
EU General Court Jurisdiction Expanded To VAT Cases
The General Court of the European Union will be able to make preliminary rulings in cases involving the EU's common system of value-added taxes starting Oct. 1, following an expansion of the court's jurisdiction.
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August 14, 2024
Pros Lament Lack Of Ownership Clarity In New EU Law
The lack of a clear beneficial ownership definition in new European Union legislation designed to speed up the repayment of withholding taxes represents a missed opportunity — and could cause confusion for investors about whether they are in fact eligible for a refund, tax professionals say.
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August 14, 2024
Other Price Rises Offset German Tampon VAT Cut, Study Says
Germany's reduction in the value-added tax on female sanitary products, such as tampons, has led to higher prices on panty liners, a Munich-based think tank said in a news release Wednesday.
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August 13, 2024
Walz Backed Tax Hikes Funding Plans For Children, Families
As Minnesota's governor, Democrat Tim Walz, now the presumed vice presidential nominee of his party, separated himself from most other governors by signing into law numerous tax increases funding progressive priorities such as a paid family leave plan and the nation's largest child tax credit.
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August 13, 2024
Treasury's Loss Rules Take Broad Approach To Min. Tax Deal
The U.S. Treasury Department recently dashed the hopes of multinational corporations seeking regulations that would have carved out an international minimum tax agreement from interacting with long-standing domestic rules aimed at preventing companies from using the same economic loss twice.
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August 13, 2024
Firm Asks Court To Reconsider $1.5M Freeze In Tax Dispute
A Baltimore law firm that sued the IRS for freezing $1.5 million in its operating account to satisfy a client's tax debts told a Maryland federal court it was "dead wrong" in denying the firm's request to release the money without going to trial.
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August 13, 2024
Developing Countries Defend 3-Year Deadline For UN Tax Pact
Three years is enough time to finish writing a United Nations framework convention on international tax cooperation, Brazil, India, Nigeria and other developing countries said Tuesday in defense of a proposed timeline that was criticized by Canada, the U.S. and France.
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August 13, 2024
Canada Seeking Comments On Global Min. Tax, Capital Gains
Canada's government is seeking comments from the public on a wide range of tax proposals included in its 2024 budget, including the introduction of the OECD's global minimum tax on large multinational corporations and adjustments to the country's taxation of capital gains, the government announced.
Expert Analysis
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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.
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Lean Into The 'Great Restoration' To Retain Legal Talent
As the “great resignation,” in which employees voluntarily left their jobs in droves, has largely dissipated, legal employers should now work toward the idea of a “great restoration,” adopting strategies to effectively hire, onboard and retain top legal talent, says Molly McGrath at Hiring & Empowering Solutions.
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Fishing Makes Me A Better Lawyer
Atop the list of ways fishing makes me a better lawyer is the relief it offers from the chronic stress of a demanding caseload, but it has also improved my listening skills and patience, and has served as an exceptional setting for building earnest relationships, says Steven DeGeorge at Robinson Bradshaw.
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A Healthier Legal Industry Starts With Emotional Intelligence
The legal profession has long been plagued by high rates of mental health issues, in part due to attorneys’ early training and broader societal stereotypes — but developing one’s emotional intelligence is one way to foster positive change, collectively and individually, says attorney Esperanza Franco.