International

  • September 18, 2024

    Tax Chiefs Eye Crypto Payment Cos., OTC Traders, IRS Says

    Tax investigators in the U.S., U.K., Canada, Australia and the Netherlands are preparing guidance on red flags for cryptocurrency payment providers and over-the-counter trading desks following a joint operation this week, a special agent with the Internal Revenue Service said Wednesday.

  • September 18, 2024

    Tax Court Wrongly Denied Premium Deduction, 5th Circ. Told

    A Texas couple asked the Fifth Circuit on Wednesday to reverse a U.S. Tax Court decision denying their bid to deduct more than $1 million in premiums paid to insurance companies they owned, arguing the Tax Court misclassified underlying insurance arrangements.

  • September 18, 2024

    Most Large Aussie Companies Paying Correct Tax Amounts

    The Australian Taxation Office has a high or medium level of assurance that 86% of the country's largest taxpayers paid the correct amount of income taxes in 2024, based on recent reviews.

  • September 18, 2024

    House GOP Vows Blowback Over OECD's Min. Tax Backstop

    House Republicans again warned the OECD that Congress will retaliate against countries that implement a backstop measure to the 15% global minimum tax, saying China will cheat the system and it will cost U.S. taxpayers about $120 billion.

  • September 18, 2024

    Estonia Implementing 2% Profit Tax To Fund Security

    Companies in Estonia will need to pay a 2% tax on their accounting profits starting in 2026 in order to boost investment in the country's defense measures, its Ministry of Finance said.

  • September 18, 2024

    Country-By-Country Reports In Place In Over 115 Jurisdictions

    More than 115 tax jurisdictions require large multinational entities to submit country-by country reports in line with the Organization for Economic Cooperation and Development standards as part of the group's fight against tax base erosion and profit shifting, the OECD reported.

  • September 18, 2024

    Colombia Should Lower 35% Corporate Tax Rate, OECD Says

    Colombia can reignite the since-slowed growth it experienced following the COVID-19 pandemic through a series of tax changes, in particular lowering its 35% corporate income tax as part of an overall rebalancing of the tax burden from corporate to personal income, according to the OECD.

  • September 18, 2024

    Latham Adds A&O Shearman Energy Group Co-Lead In DC

    Latham & Watkins LLP has hired the former co-head of Allen Overy Shearman Sterling's U.S. energy, natural resources and infrastructure group to its team of transactional tax partners based in Washington, D.C., the firm announced Monday.

  • September 18, 2024

    8th Circ. Considers Chevron's End In 3M's $24M Tax Case

    The Eighth Circuit signaled it would consider an argument by 3M that the U.S. Supreme Court's overturning of Chevron deference warranted a reversal in a transfer pricing case in which 3M is challenging the IRS' reallocation of $24 million from a Brazilian affiliate.

  • September 18, 2024

    Fixing UK Labor Market Could Raise £16B, Report Says

    The U.K. labor market has lost almost a million workers since the COVID-19 pandemic, but reversing this could raise more than £16 billion ($21.1 billion) in tax receipts, a research center said Wednesday.

  • September 18, 2024

    Dutch Government Issues Tax Cuts In First Budget

    The new Dutch government issued its first budget since the 2023 elections, including plans to cut taxes on earnings and raise the limit on certain corporate tax deductions.

  • September 17, 2024

    Tax Court Denies Mineral Co.'s $1.1M Microcaptive Deduction

    A mineral rights leasing company set up by an Oklahoma oil businessman can't take a $1.1 million deduction for what was presented as a microcaptive insurance transaction, the U.S. Tax Court ruled, saying the transaction was not a legitimate insurance arrangement.

  • September 17, 2024

    Cos. Risk Offside Call On Contractor Tax After HMRC Win

    The U.K. Supreme Court's decision Monday that Premier League referees count as employees for tax purposes means many companies may have to reassess their arrangements with contractors or risk higher tax costs in the future, tax experts say.

  • September 17, 2024

    Competitiveness Outranks Climate In New EU Commission

    European Commission President Ursula von der Leyen shifted her focus from climate change to boosting competitiveness as she proposed her team of commissioners for the next five-year mandate Tuesday, handing out key jobs covering everything from competition enforcement to trade policy.

  • September 16, 2024

    Film Producer, Accountant Hid $25M From IRS, DOJ Alleges

    A film producer who sold shares in the production company he cofounded for $25 million schemed with an Australian accountant to hide the proceeds from U.S. authorities in Swiss bank accounts, causing the IRS to lose out on some $5 million, according to the DOJ.

  • September 16, 2024

    Apple Ruling May Embolden EU's Tax Policing, Experts Say

    The European Court of Justice's ruling against Apple and Ireland last week runs contrary to its logic in a 2022 state aid ruling, potentially giving the European Commission a reason to think it can decide tax norms across Europe, tax experts said.

  • September 16, 2024

    Hospitality Sector Faces Almost £1B 'Tax Bombshell' In April

    Many companies in the hospitality sector are set to be hit with huge tax bills in April 2025 when business rates relief is phased out, an industry group said Monday.

  • September 16, 2024

    Jet Fuel Tax Could Raise Almost £6B A Year, Report Says

    HM Treasury could raise up to £5.9 billion ($7.8 billion) a year by imposing tax on jet fuel to match the duty paid by motorists, according to a think tank report published Monday.

  • September 16, 2024

    IRS Cancels Hearing On 'Basket Contract' Transactions Rule

    The Internal Revenue Service canceled a hearing on proposed rules that would flag what are known as basket option contracts as potentially abusive listed transactions, according to a notice released Monday.

  • September 16, 2024

    Football Referees Can Be Employees, Top UK Court Rules

    Referees for English football games can legally be considered employees, obliging the company they work for to deduct taxes from their pay, the U.K.'s highest court ruled Monday.

  • September 13, 2024

    The 2024 Regional Powerhouses

    The law firms on Law360's list of 2024 Regional Powerhouses reflected the local peculiarities of their states while often representing clients in deals and cases that captured national attention.

  • September 13, 2024

    EU Actors Lobby Hard For Top Jobs in New Commission

    European Union lawmakers and national governments are lobbying intensely to pull top jobs and policy their way as the new European Commission is formed for the next five years.

  • September 13, 2024

    HMRC Seeks Comments On Top-Up Tax Guidance

    HM Revenue & Customs is seeking comments on new draft guidance on the multinational top-up tax as part of implementing the global minimum corporate tax rate.

  • September 13, 2024

    EU Finance Ministers Boycott Hungary Meeting Over Russia

    Most European Union finance ministers protested on Friday against what they see as Hungary's Russia-friendly politics by boycotting a meeting with their EU peers in the country's capital, Budapest.

  • September 13, 2024

    Freeths Hires McNulty As Pensions Director In London

    Freeths LLP has appointed Sean McNulty, a former legal director at Blake Morgan as a pensions director in its London office, a move it believes will bolster its retirement income business.

Expert Analysis

  • Pro Bono Work Is Powerful Self-Help For Attorneys

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    Oct. 22-28 is Pro Bono Week, serving as a useful reminder that offering free legal help to the public can help attorneys expand their legal toolbox, forge community relationships and create human connections, despite the challenges of this kind of work, says Orlando Lopez at Culhane Meadows.

  • The Pop Culture Docket: Judge Espinosa On 'Lincoln Lawyer'

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    The murder trials in Netflix’s “The Lincoln Lawyer” illustrate the stark contrast between the ethical high ground that fosters and maintains the criminal justice system's integrity, and the ethical abyss that can undermine it, with an important reminder for all legal practitioners, say Judge Adam Espinosa and Andrew Howard at the Colorado 2nd Judicial District Court.

  • How And Why Your Firm Should Implement Fixed-Fee Billing

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    Amid rising burnout in the legal industry and client efforts to curtail spending, pivoting to a fixed-fee billing model may improve client-attorney relationships and offer lawyers financial, logistical and stress relief — while still maintaining profit margins, say Kevin Henderson and Eric Pacifici at SMB Law Group.

  • How Law Firms Can Use Account-Based Marketing Strategies

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    Amid several evolving legal industry trends, account-based marketing can help law firms uncover additional revenue-generating opportunities with existing clients, with key considerations ranging from data analytics to relationship building, say Jennifer Ramsey at stage LLC and consultant Gina Sponzilli.

  • Strategic Succession Planning At Law Firms Is Crucial

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    Senior partners' reluctance to retire, the rise of the nonequity partner tier and generational differences in expectations are all contributing to an increasing number of departures from BigLaw, making it imperative for firms to encourage retirement among senior ranks and provide clearer leadership pathways to junior attorneys, says Laura Leopard at Leopard Solutions.

  • Maximizing Law Firm Profitability In Uncertain Times

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    As threats of an economic downturn loom, firms can boost profits by embracing the power of bottom-line management and creating an ecosystem where strategic financial oversight and robust timekeeping practices meet evolved client relations, says Shireen Hilal at Maior Strategic Consulting.

  • 5th Circ. Ruling Reminds Attys That CBP Can Search Devices

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    The Fifth Circuit’s recent Malik v. Department of Homeland Security decision adds to the chorus of federal courts holding that border agents don’t need a warrant to search travelers’ electronic devices, so attorneys should consider certain special precautions to secure privileged information when reentering the U.S., says Jennifer Freel at Jackson Walker.

  • Enforcement Of International Tax Reporting Is Heating Up

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    Since the U.S. Supreme Court’s February decision in Bittner v. U.S. changed how penalties for failure to report offshore accounts are calculated, recent developments suggest the government is preparing to step up enforcement and vigorously pursue the collection of resulting penalties, say Daniel Silva and Agustin Ceballos at Buchalter.

  • IRS Notice Clarifies R&E Amortization, But Questions Remain

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    The IRS and Treasury Department’s recent notice clarifying the treatment of specified research and experimental expenditures under Section 174 provides taxpayers and practitioners with substantive guidance, but it misses the mark in delineating which expenditures are amortizable, say attorneys at Eversheds Sutherland.

  • Preparing Your Legal Department For Pillar 2 Compliance

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    Multinational entities should familiarize themselves with Pillar Two of the Organization for Economic Cooperation and Development’s BEPs 2.0 project and prepare their internal legal tracking systems for related reporting requirements that may go into effect as early as January, says Daniel Robyn at Ernst & Young.

  • What Large Language Models Mean For Document Review

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    Courts often subject parties using technology assisted review to greater scrutiny than parties conducting linear, manual document review, so parties using large language models for document review should expect even more attention, along with a corresponding need for quality control and validation, say attorneys at Sidley.

  • Participating In Living History Makes Me A Better Lawyer

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    My role as a baron in a living history group, and my work as volunteer corporate counsel for a book series fan association, has provided me several opportunities to practice in unexpected areas of law — opening doors to experiences that have nurtured invaluable personal and professional skills, says Matthew Parker at the Nebraska Department of Health and Human Services.

  • Private Equity Owners Can Remedy Law Firms' Agency Issues

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    Nonlawyer, private-equity ownership of law firms can benefit shareholders and others vulnerable to governance issues such as disparate interests, and can in turn help resolve agency problems, says Michael Di Gennaro at The Law Practice Exchange.

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