International
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June 28, 2024
UK Appeals Court Rules Businesses Can't Claim Allowances
Two U.K. businesses may not claim capital allowances from a transaction that was carried out as part of a marketed tax avoidance scheme, a British appeals court ruled Friday, overturning a lower court's decision.
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June 28, 2024
Chevron Ruling No Sea Change For Tax Court, Judge Says
The U.S. Tax Court will continue to rely on the IRS and Treasury's expertise in the tax code following the U.S. Supreme Court's landmark decision to overturn the 40-year-old Chevron doctrine that directed courts to defer to federal agencies' interpretations of ambiguous law, a judge said Friday.
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June 28, 2024
Taxation With Representation: Kirkland, Vinson, Skadden
In this week's Taxation with Representation, Aareal Bank AG and Advent International sell a property management and maintenance software company, Webtoon Entertainment Inc. and Tamboran Resources Corp. price initial public offerings, SM Energy Company acquires oil and gas assets, and Nokia sells Alcatel Submarine Networks to the French state.
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June 28, 2024
Australia Seeks Feedback On Renewable Energy Tax Credits
Australia's government is looking for public input on plans to offer tax breaks tied to renewable hydrogen and critical mineral production as part of the country's push to boost its green energy industry, the country's Treasury announced Friday.
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June 28, 2024
Jamaica, Turkey Taken Off Financial Crime Watch List
An intergovernmental task force on money laundering and other forms of financial crime said Friday that Jamaica and Turkey have been taken off the list of jurisdictions it monitors for compliance with international security standards.
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June 28, 2024
Estate Owes $4.9M For Son-Of-Boss Scheme, US Says
An estate owes $4.9 million in tax liabilities for a couple's scheme to artificially cancel out their capital gains, the federal government said in a complaint in Michigan federal court, arguing that the Son-of-Boss scheme constitutes fraud and its proceeds aren't entitled to bankruptcy protection.
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June 28, 2024
EU Leaders Nominate President Von Der Leyen For 2nd Term
European Union leaders nominated European Commission President Ursula von der Leyen for a second term and named their picks for two other top jobs in the bloc that will steer European policy for the next five years, including tax policy and economic sanctions.
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June 28, 2024
Supreme Court Strikes Down Chevron Deference
The U.S. Supreme Court on Friday overturned a decades-old precedent that instructed judges about when they could defer to federal agencies' interpretations of law in rulemaking, depriving courts of a commonly used analytic tool and leaving lots of questions about what comes next.
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June 27, 2024
Aussie Betting Site Can't Duck Taxes Tied To News Corp. Sale
Trustees associated with an Australia-based gambling website owe capital gains taxes on the AU$31 million ($20.6 million) sale of the business to News Corp., an Australian court ruled, finding the parties lacked an affiliated relationship that could warrant an exception.
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June 27, 2024
Congress Shouldn't Rush OECD Tax Package, Group Says
Congress should avoid "rubber-stamping" the two pillars of the Organization for Economic Cooperation and Development's plan to fight tax base erosion and profit shifting and instead gather more information on its impact on the U.S., a conservative advocacy group said Thursday.
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June 27, 2024
IRS Tells 10th Circ. To Deny Liberty Global's $110M Refund Bid
The U.S. government urged the Tenth Circuit on Thursday to reject telecommunication giant Liberty Global's push for a $110 million tax refund, arguing a lower court correctly deduced that the company's business restructurings were carried out solely to avoid tax.
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June 27, 2024
$2.1B Danish Tax Fraud Suspect Won't Testify, Court Says
A New York federal court denied dueling requests from U.S. pension plan investors accused of participating in a $2.1 billion Danish tax fraud scheme and from Denmark's tax agency to bring in the man that both sides say masterminded the scheme, or to bring in one of his employees.
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June 27, 2024
Ex-Skadden Tax Head And M&A Pro Joins Freshfields In NY
Freshfields Bruckhaus Deringer LLP has added the former head of the tax practice at Skadden Arps Slate Meagher & Flom LLP as a partner this week, who brings to the role experience in deals like 21st Century Fox's $71 billion acquisition by Disney and the merger of T-Mobile and Sprint.
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June 27, 2024
New FATCA Deal Requires US Banks To Share Info With Swiss
The United States and Switzerland signed a Foreign Account Tax Compliance Act agreement that will require U.S. banks to share financial account information on a bilateral basis, Switzerland's Federal Department of Finance announced Thursday.
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June 27, 2024
Algeria Commits To OECD Tax Treaty Standards
Algeria signed on to the Organization for Economic Cooperation and Development's multilateral convention Thursday, committing to implement the group's standards to fight base erosion and profit shifting in bilateral tax treaties, the OECD said.
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June 27, 2024
New EU Chair Wants VAT Deal Despite Calendar Omission
The incoming chair of meetings of European Union countries wants agreement on a proposal to require that platform companies such as Airbnb and Uber collect value-added tax for service providers despite leaving it off its work calendar, a spokesperson said.
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June 26, 2024
EU Court Tosses Spanish Shipping Cos. State Aid Appeal
A European court on Wednesday once again dismissed a 2014 challenge to the European Commission's move to block a Spanish tax scheme benefiting Spanish shipbuilders and their suppliers.
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June 26, 2024
Repatriation Tax Ruling May Sway State Wealth Tax Debates
The U.S. Supreme Court's upholding of the federal repatriation tax could indirectly affect state tax policy discussions, including by influencing consideration of wealth taxes and encouraging states to keep potential due process issues in mind when enacting tax legislation.
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June 26, 2024
Pepsi's Royalty Tax Liability Overturned By Australian Panel
A Federal Court of Australia judge incorrectly ruled that payments for beverage concentrate between Pepsi subsidiaries in Australia and Singapore included the license to use Pepsi's trademark and so triggered royalty taxes, a panel of the court ruled Wednesday.
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June 26, 2024
Fed. Circ. Denies Contractor's $37M Tax Reimbursement Bid
A U.S. State Department armed security contractor is not entitled to $37 million in reimbursement tied to tax payments to the Afghan government because the contractor's parent company, not the company itself, incurred the costs associated with the payments, the Federal Circuit said Wednesday.
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June 26, 2024
Medical Device Co. To Pay $935K Atty Fees In Tax Fraud Suit
A medical equipment company's leaders will pay $935,000 in attorney fees to investors' counsel after mediating a settlement in a proposed class action alleging the company breached fiduciary duty in failing to disclose its former CEO's involvement in a tax fraud dispute with Denmark.
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June 26, 2024
Kenya President Backs Off Finance Bill After Fatal Protests
Kenyan President William Ruto said Wednesday that he will withdraw a controversial finance bill that included tax hikes that inspired mass protests, including storming the country's Parliament building leaving multiple people dead, according to local news reports.
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June 26, 2024
EU Justice Head Loses Bid To Lead Human Rights Group
The European Union's justice commissioner failed in his bid to lead a European human rights organization and returned Wednesday from his leave of absence for the remaining four months of his term as commissioner.
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June 26, 2024
EU State Auditors Must Respect Tax Incentives, Lawyer Says
European Union countries need to make sure that their tax authorities are supporting incentive programs, such as those related to research and development, rather than interpreting laws in inconsistent ways, a tax lawyer said Wednesday.
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June 26, 2024
Irish Pick New Finance Minister After Former Heads To EU
Ireland picked a current junior minister as its new finance minister, the ministry confirmed to Law360 on Wednesday, one day after the government nominated the outgoing finance minister to serve on the next European Commission.
Expert Analysis
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The Art Of Asking: Leveraging Your Contacts For Referrals
Though attorneys may hesitate to ask for referral recommendations to generate new business, research shows that people want to help others they know, like and trust, so consider who in your network you should approach and how to make the ask, says Rebecca Hnatowski at Edwards Advisory.
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Unpacking The Bill To Extend TCJA's Biz-Friendly Tax Breaks
Attorneys at Skadden examine how a bipartisan bill currently being considered by the U.S. Senate to save the Tax Cuts and Jobs Act's tax breaks for research and development costs, and other expiring business-friendly provisions, would affect taxpayers.
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Deciding What Comes At The End Of WTO's Digital Tariff Ban
Companies that feel empowered by the World Trade Organization’s recent two-year extension of the ban on e-commerce tariffs should pay attention to current negotiations over what comes after the moratorium expires, as these agreements will define standards in international e-commerce for years to come, say Jan Walter, Hannes Sigurgeirsson and Kulsum Gulamhusein at Akin Gump.
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4 Ways To Refresh Your Law Firm's Marketing Strategy
With many BigLaw firms relying on an increasingly obsolete marketing approach that prioritizes stiff professionalism over authentic connection, adopting a few key communications strategies to better connect with today's clients and prospects can make all the difference, say Eric Pacifici and Kevin Henderson at SMB Law.
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This Earth Day, Consider How Your Firm Can Go Greener
As Earth Day approaches, law firms and attorneys should consider adopting more sustainable practices to reduce their carbon footprint — from minimizing single-use plastics to purchasing carbon offsets for air travel — which ultimately can also reduce costs for clients, say M’Lynn Phillips and Lisa Walters at IMS Legal Strategies.
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Cum-Ex Prosecutions Storm Shows No Sign Of Abating
The ongoing trial of Sanjay Shah in Denmark is a clear indicator that efforts remain focused on holding to account the alleged architects and beneficiaries of cum-ex trading, and with these prosecutions making their way across Europe, it is a more turbulent time now than ever, says Niall Hearty at Rahman Ravelli.
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Practicing Law With Parkinson's Disease
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.
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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.
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For Lawyers, Pessimism Should Be A Job Skill, Not A Life Skill
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.
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Requiring Leave To File Amicus Briefs Is A Bad Idea
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.
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4 Ways To Motivate Junior Attorneys To Bring Their Best
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.
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Former Minn. Chief Justice Instructs On Writing Better Briefs
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.
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Stay Interviews Are Key To Retaining Legal Talent
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.