International
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August 28, 2024
Atty Can't Escape Danish Tax Agency's $2.1B Tax Fraud Suit
An attorney in a $2.1 billion tax fraud case brought by the Danish tax authority cannot argue that a suit filed against him as an individual should be dismissed because it was filed late, a New York federal court ruled.
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August 27, 2024
Gov't Says Doctor Can't Escape Contempt Fine In FBAR Case
A doctor challenging his $20,000 civil contempt fine for failing to follow a court order to repatriate money from his foreign bank account to cover $1.1 million in tax liabilities shouldn't be allowed to escape the penalty, the U.S. government argued Tuesday.
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August 27, 2024
Canadian Grocery Giant's Bank Wins Appeal Over Tax Credits
The Tax Court of Canada incorrectly decided that a bank owned by the country's largest supermarket chain, Loblaw, couldn't claim tax credits aimed at exempting commercial purchases for payments the bank made in a customer rewards program, a Federal Court of Appeal panel ruled.
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August 27, 2024
OECD Says Malaysia Should Resume GST, End Fuel Subsidies
With spending pressures rising, Malaysia should look to increase its tax revenues through measures including a reintroduction of its goods and services tax, as well as push to minimize its climate impact by eliminating fuel subsidies, the Organization for Economic Cooperation and Development said Tuesday.
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August 27, 2024
Treasury Asked To Scrap Stock Buyback Tax's Funding Rule
Business groups urged the U.S. Treasury Department on Tuesday to remove what's known as the funding rule in forthcoming final regulations on the stock buyback tax, saying the provision would go beyond Congress' intentions for the levy, which aims to deter companies from giving outsize rewards to shareholders.
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August 27, 2024
Croatia, HK, Others Address Hurtful Tax Regimes, OECD Says
Five tax jurisdictions, including Croatia and Hong Kong, have made progress to address various harmful tax practices, the Organization for Economic Cooperation and Development said Tuesday.
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August 27, 2024
Germany Proposes Investment Tax Changes To Attract VC
Germany would adjust its tax laws in an attempt to better attract venture capital and investments into renewable energies under a proposal published Tuesday by the country's finance ministry as part of a planned "growth initiative."
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August 27, 2024
Starmer Warns Of 'Painful' Budget As UK Braces For Tax Hikes
U.K. Prime Minister Keir Starmer warned Tuesday of "painful" decisions to plug budget gaps, including tax increases and spending cuts, looming in the Oct. 30 budget statement.
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August 27, 2024
Gov't Urged To Reform Pension Tax To Fill Budget Gaps
The Labour government should reform £66 billion ($87 billion) worth of pension tax relief to raise extra revenue to help plug the black hole in public finances, a think tank affiliated to the party has said.
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August 26, 2024
Varian Entitled To Foreign Dividend Break, Tax Court Says
California-based medical device company Varian Medical Systems is entitled to a deduction for dividends received from its foreign subsidiaries, the U.S. Tax Court ruled Monday in a unanimous opinion.
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August 26, 2024
US Should Extend Expiring TCJA Tax Cuts, Chamber Says
The expiration of the 2017 Tax Cuts and Jobs Act in 2025 gives the next Congress an opportunity to pass pro-growth tax policies, the U.S. Chamber of Commerce said Monday.
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August 26, 2024
Kyocera's Gross-Up Doesn't Grant $143M Tax Break, US Says
Electronics maker Kyocera cannot be allowed to take a $143 million tax deduction for distributions received under a 2017 tax law based on a separate statute's gross-up for paid foreign tax credits, the government told a South Carolina federal court.
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August 26, 2024
New Zealand Considers OECD Crypto Reporting Framework
New Zealand would implement the Organization for Economic Cooperation and Development's framework for automatically exchanging financial information regarding crypto-assets under a proposal the country's revenue minister sent to its Legislature on Monday.
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August 26, 2024
Canada Planning 100% Surtax On Chinese EVs, 25% On Steel
Canada plans to implement a 100% surtax on imported Chinese electric vehicles and a 25% surtax on Chinese steel and aluminum as part of a package intended to protect Canadian industry from unfair competition, the country's Department of Finance said Monday.
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August 23, 2024
Chamber Backs Doctor In Tax Court Economic Substance Suit
The U.S. Chamber of Commerce lent its support to an eye doctor and his wife's U.S. Tax Court case disputing accuracy-related penalties that the Internal Revenue Service plans to impose on their microcaptive insurance arrangements for lacking economic substance.
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August 23, 2024
IRS Spinoff Guidance Sparks Worries About Short-Term Debt
Companies that intend to give creditors equity tied to a spinoff transaction won't get early tax-free approval if the exchange involves recently acquired debt under IRS guidance that practitioners say draws an arbitrary line without accounting for ordinary business operations.
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August 23, 2024
Alvarez & Marsal Adds Transfer Pricing Expert From EY
A former EY partner joined Alvarez & Marsal LLC to serve as managing director of its transfer pricing line of services in its New York office, the firm announced.
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August 23, 2024
45% Of US Biz Income Abroad In Tax Havens, Data Shows
U.S. multinational corporations booked about 45% of their $1.33 trillion in net foreign income in 2022 in low-tax jurisdictions where around 1.7% of their employees are located, according to an analysis of data released Friday by the Bureau of Economic Analysis.
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August 23, 2024
German Official Backs Anti-Abuse Tax Rules Roll-Back Review
A German Federal Ministry of Finance official agreed with tax experts' proposal to review the anti-abuse provisions of international tax law in order to potentially roll them back, especially with the global corporate minimum tax going into force across the European Union.
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August 23, 2024
Taxation With Representation: Latham, Wachtell, Paul Weiss
In this week's Taxation With Representation, Arch Resources merges with Consol Energy in a deal worth $5.2 billion, Advanced Micro Devices agrees to purchase ZT Systems for $4.9 billion, and Japanese tobacco company JT Group inks a deal to buy Vector Group for $2.4 billion.
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August 23, 2024
HMRC Can Be Liable For Damage To Biz Shut Over £7.4M Debt
The tax authority cannot lift a court order that requires it to repay a payroll business damages for losses suffered after it was put into provisional liquidation, as a court found on Friday that it had failed to pursue that action for law enforcement purposes.
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August 22, 2024
Switzerland Expects 3.2% Tax Receipt Increase In 2025
Switzerland expects to generate 85.7 billion Swiss francs ($100.6 billion) in tax receipts in 2025, an increase of 3.2% over the 2024 budget, with the biggest growth projected to come from personal income taxes, the country's Federal Finance Administration said Thursday.
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August 22, 2024
Kenya's Justices May Ax Part Of Tax Act That Set Off Unrest
The Supreme Court of Kenya agreed to stay a lower court's ruling declaring unconstitutional the government's entire 2023 tax package, which sparked deadly nationwide protests, but it looks likely to scrap at least part of the law next month, attorneys told Law360 on Thursday.
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August 22, 2024
Australian Legislators Advance Enactment Of Global Min. Tax
Australia would enact the Organization for Economic Cooperation and Development's 15% global corporate minimum tax on large multinational entities, known as Pillar Two, under three bills passed Thursday by the country's House of Representatives.
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August 22, 2024
EU Decision Keeps Tax Relief For UK Investment Schemes
The European Commission will allow U.K. government-backed programs that encourage private investment in small companies to continue offering favorable tax terms for investors, according to a decision published Thursday.
Expert Analysis
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Loper Bright Limits Federal Agencies' Ability To Alter Course
The U.S. Supreme Court's recent decision to dismantle Chevron deference also effectively overrules its 2005 decision in National Cable & Telecommunications Association v. Brand X, greatly diminishing agencies' ability to change regulatory course from one administration to the next, says Steven Gordon at Holland & Knight.
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After Chevron: Delegation Of Authority And Tax Regulators
The U.S. Department of the Treasury and the Internal Revenue Service will face higher standards following Loper Bright’s finding that courts should determine whether agency rules meet the best possible interpretation of the tax code, as well as the scope of the authority delegated by Congress, says Edward Froelich at McDermott.
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Lawyers Can Take Action To Honor The Voting Rights Act
As the Voting Rights Act reaches its 59th anniversary Tuesday, it must urgently be reinforced against recent efforts to dismantle voter protections, and lawyers can pitch in immediately by volunteering and taking on pro bono work to directly help safeguard the right to vote, says Anna Chu at We The Action.
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How To Grow Marketing, Biz Dev Teams In A Tight Market
Faced with fierce competition and rising operating costs, firms are feeling the pressure to build a well-oiled marketing and business development team that supports strategic priorities, but they’ll need to be flexible and creative given a tight talent market, says Ben Curle at Ambition.
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Rock Climbing Makes Me A Better Lawyer
Rock climbing requires problem-solving, focus, risk management and resilience, skills that are also invaluable assets in my role as a finance lawyer, says Mei Zhang at Haynes and Boone.
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Contract Disputes Recap: Preserving Payment Rights
Stephanie Magnell and Zachary Jacobson at Seyfarth examine three recent decisions that together illustrate the importance of keeping accurate records and adhering to contractual procedures to avoid inadvertently waiving contractual rights to cost reimbursements or nonroutine payments.
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Think Like A Lawyer: Dance The Legal Standard Two-Step
From rookie brief writers to Chief Justice John Roberts, lawyers should master the legal standard two-step — framing the governing standard at the outset, and clarifying why they meet that standard — which has benefits for both the drafter and reader, says Luke Andrews at Poole Huffman.
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Lead Like 'Ted Lasso' By Embracing Cognitive Diversity
The Apple TV+ series “Ted Lasso” aptly illustrates how embracing cognitive diversity can be a winning strategy for teams, providing a useful lesson for law firms, which can benefit significantly from fresh, diverse perspectives and collaborative problem-solving, says Paul Manuele at PR Manuele Consulting.
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Now More Than Ever, Lawyers Must Exhibit Professionalism
As society becomes increasingly fractured and workplace incivility is on the rise, attorneys must champion professionalism and lead by example, demonstrating how lawyers can respectfully disagree without being disagreeable, says Edward Casmere at Norton Rose.
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Reading Between The Lines Of Justices' Moore Ruling
The U.S. Supreme Court's recent Moore v. U.S. decision, that the Internal Revenue Code Section 965 did not violate the 16th Amendment, was narrowly tailored to minimally disrupt existing tax regimes, but the justices' various opinions leave the door open to future tax challenges and provide clues for what the battles may look like, say Caroline Ngo and Le Chen at McDermott.
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A Midyear Forecast: Tailwinds Expected For Atty Hourly Rates
Hourly rates for partners, associates and support staff continued to rise in the first half of this year, and this growth shows no signs of slowing for the rest of 2024 and into next year, driven in part by the return of mergers and acquisitions and the widespread adoption of artificial intelligence, says Chuck Chandler at Valeo Partners.
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States Should Loosen Law Firm Ownership Restrictions
Despite growing buzz, normalized nonlawyer ownership of law firms is a distant prospect, so the legal community should focus first on liberalizing state restrictions on attorney and firm purchases of practices, which would bolster succession planning and improve access to justice, says Michael Di Gennaro at The Law Practice Exchange.
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After Chevron: Uniform Tax Law Interpretation Not Guaranteed
The loss of Chevron deference will significantly alter the relationship between the IRS, courts and Congress when it comes to tax law, potentially precipitating more transparent rulemaking, but also provoking greater uncertainty due to variability in judicial interpretation, say Michelle Levin and Carneil Wilson at Dentons.