International
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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.
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October 24, 2024
Dutch Gov't Seeks Feedback On Crypto Reporting Rules
The Netherlands is looking for input on a proposal that would implement European Union rules requiring crypto-asset service providers to collect, check and share their users' data with the country's tax authority, the Dutch Ministry of Finance said Thursday.
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October 24, 2024
Aussie Board Seeks Input On Tax Pro Code Update Guidance
The Australian Tax Practitioners Board is looking for feedback on guidance related to six amendments to the country's tax professional code of conduct that were made in response to the PwC document leak scandal, the board said Thursday.
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October 24, 2024
119K Residents Didn't Report Foreign Accounts, HMRC Says
Around 119,000 U.K. residents failed to declare their foreign accounts in fiscal year 2018-19 with HM Revenue & Customs, the British tax authority said Thursday.
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October 24, 2024
Sweden Moves To Suspend Tax Treaty With Russia
Sweden is looking to suspend its double-tax treaty with Russia in response to Russia's cessation of parts of their treaty last year, Sweden's Ministry of Finance said Thursday.
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October 24, 2024
MVP: Sidley's Rachel D. Kleinberg
Rachel D. Kleinberg, a co-leader of the global tax practice at Sidley Austin LLP, headed up a tax team to represent investors in a consortium that led to the $6.05 billion sale of the NFL's Washington Commanders, earning her a spot as one of the 2024 Law360 Tax MVPs.
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October 24, 2024
Charles Russell Brings On Tax Specialist From Sheridans
Charles Russell Speechlys LLP hired a partner from Sheridans as part of expanding its London tax practice to support its strategy focused on private capital, the firm said.
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October 24, 2024
Mining Eligible In Final Regs For Energy Manufacturing Credit
The U.S. Treasury Department's final rules released Thursday on a valuable tax credit for manufacturing key components and materials used in clean energy technologies allow producers to take into account the costs to mine and extract critical minerals.
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October 23, 2024
IRS To Split Pass-Through, Energy Credit Work Into 2 Units
The IRS is planning to split up its Pass-Throughs and Special Industries office into two separate divisions, including one that will focus in part on energy credits enacted under the 2022 landmark climate law, an agency official said Wednesday.
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October 23, 2024
COST Urges Justices To Hear IBM, Disney Appeals Of NY Tax
New York's method of taxing IBM and The Walt Disney Co.'s royalties received from foreign affiliates resulted in an unconstitutional discrimination against interstate commerce that warrants U.S. Supreme Court scrutiny, the Council on State Taxation told the justices Wednesday.
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October 23, 2024
Microsemi's Fines Mostly Adhered To Rules, Tax Court Says
The Internal Revenue Service obtained the proper written approval of penalties on most of the tax code violations it brought against semiconductor manufacturer Microsemi but left room for doubt on two penalties, the U.S. Tax Court said.
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October 23, 2024
ECJ Won't Call Off Clawback Of Portugal's Tax Breaks
The European Court of Justice declined to overturn a European Commission decision that Portugal must claw back tax breaks provided in a free trade zone to companies with no local economic activity, as those breaks violated the bloc's state aid rules, according to a judgment issued Wednesday.
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October 23, 2024
Australian Greens Support Digital Tax On Tech Cos.
The Australian Greens party recommended that the country's government pursue a digital services tax similar to those in France and Canada as a way to make companies such as Meta pay their "fair share."
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October 23, 2024
EU Tax Nominee Vows Corp. Tax Simplification, Pillar 1 Work
The nominee to serve as the European Union's next tax commissioner pledged to simplify corporate rules and affirmed his support for the reallocation of taxing rights known as Pillar One in remarks to the European Parliament.
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October 23, 2024
ABA Tax Section Pushes IRS To Narrow Pillar 2 Regulations
Proposed regulations outlining when foreign taxes under the Pillar Two international minimum tax agreement trigger U.S. rules against benefiting twice from the same economic loss should be narrowed to limit their applicability, the American Bar Association Tax Section told the IRS.
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October 23, 2024
IRS Grants Tax-Exempt Entities Relief From Corp. AMT Filing
Tax-exempt entities are not obligated to file the corporate alternative minimum tax form for the 2023 tax year with the Internal Revenue Service, but they should still maintain the document for recordkeeping purposes, the agency announced Wednesday.
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October 23, 2024
EU OKs Swedish Biogas Tax Breaks After Review
Two Swedish tax exemptions — one for nonfood-based biogas, the other for biopropane used for heating — are in line with European Union state aid rules, the European Commission said Wednesday following a probe into the measures.
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October 23, 2024
Judge Threatens To Toss Gov't's $4.9M Son-Of-Boss Claim
A federal judge warned government attorneys Wednesday that she would dismiss their case against an estate for $4.9 million in taxes if they didn't explain why they weren't actively pursuing their accusations that a Michigan couple schemed to artificially cancel out capital gains
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October 23, 2024
Jersey Adopts Global Minimum Tax
Jersey has adopted the Organization for Economic Cooperation and Development's 15% minimum tax on multinational entities making over €750 million ($808 million) annually, which will take effect in the jurisdiction in 2025.
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October 23, 2024
MVP: Sullivan & Cromwell's Eric Wang
Sullivan & Cromwell's S. Eric Wang advised clients on the tax law implications of major deals over the past year, including a transaction that created the largest gas utility company in North America, earning him a spot as one of the 2024 Law360 2024 Tax MVPs.
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October 22, 2024
8th Circ. Judge Presses IRS On 3M Transfer Pricing Tax Ruling
An Eighth Circuit judge cast doubt during oral arguments Tuesday on the government's interpretation of regulations the IRS relied on to reallocate almost $24 million of income to 3M from its Brazilian affiliate that was subject to legal restrictions on royalty payments.
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October 22, 2024
New IRS Unit Starts Work On Pass-Through Compliance
A new Internal Revenue Service unit focused on the compliance of pass-through entities of all sizes and forms, such as partnerships, S corporations and trusts, has officially started work, the agency said Tuesday.
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October 22, 2024
Brazil Eyes Shifting Talks On Wealth Taxation To UN
Brazil is campaigning for the United Nations to commit to creating a minimum tax on high-net-worth individuals in February during expected talks on the organization's burgeoning global tax convention, a Brazilian finance ministry official said Tuesday at the International Monetary Fund.
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October 22, 2024
Argentina President Dissolving, Replacing Tax Agency
Argentina's tax authority, the Federal Public Revenue Administration, will be dissolved and replaced with a new body, the country's president said, with the change causing a 34% reduction in jobs.
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October 22, 2024
Tax Court Says It Can't Rule On FBAR Challenge
The U.S. Tax Court said Tuesday that it lacks the authority to rule on a couple's claim that the Internal Revenue Service wrongly denied them a chance to challenge penalties for failing to report their foreign bank accounts.
Expert Analysis
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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.
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A Post-Mortem Analysis Of Stroock's Demise
After the dissolution of 147-year-old firm Stroock late last year shook up the legal world, a post-mortem analysis of the data reveals a long list of warning signs preceding the firm’s collapse — and provides some insight into how other firms might avoid the same disastrous fate, says Craig Savitzky at Leopard Solutions.
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SG's Office Is Case Study To Help Close Legal Gender Gap
As women continue to be underrepresented in the upper echelons of the legal profession, law firms could learn from the example set by the Office of the Solicitor General, where culture and workplace policies have helped foster greater gender equality, say attorneys at Ocean Tomo.
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Reimagining Law Firm Culture To Break The Cycle Of Burnout
While attorney burnout remains a perennial issue in the legal profession, shifting post-pandemic expectations mean that law firms must adapt their office cultures to retain talent, say Kevin Henderson and Eric Pacifici at SMB Law Group.
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Cayman Islands Off AML Risk Lists, Signaling Robust Controls
As a world-leading jurisdiction for securitization special purpose entities, the removal of the Cayman Islands from increased anti-money laundering monitoring lists is a significant milestone that will benefit new and existing financial services customers conducting business in the territory, say lawyers at Walkers Global.
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The Legal Industry Needs A Cybersecurity Paradigm Shift
As law firms face ever-increasing risks of cyberattacks and ransomware incidents, the legal industry must implement robust cybersecurity measures and privacy-centric practices to preserve attorney-client privilege, safeguard client trust and uphold the profession’s integrity, says Ryan Paterson at Unplugged.
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As Promised, IRS Is Coming For Crypto Tax Evaders
The IRS is fulfilling its promise to crack down on those who have neglected to pay taxes on cryptocurrency earnings, as demonstrated by recently imposed prison sentences, enforcement initiatives and meetings with international counterparts — suggesting a few key takeaways for taxpayer compliance, say attorneys at BakerHostetler.