International
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October 08, 2024
China Pushes Back On Turkish EV Tariffs, Targets EU Brandy
China said Tuesday that it is appealing to the World Trade Organization to halt Turkish tariffs on electric and hybrid vehicles made in the country, and it announced a temporary anti-dumping measure on European Union brandy that follows the bloc's own EV tariffs.
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October 08, 2024
Tire Seller Counts As Importer, Owes $2M Tax, 5th Circ. Says
A Houston truck sales company owes nearly $2 million in excise taxes because it qualifies as the importer of tires that it bought from a Chinese manufacturer, the Fifth Circuit ruled Tuesday in overturning the decision of a Texas federal judge.
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October 08, 2024
Loss Rule Carveouts Raise Challenges In Pillar 2, Official Says
An IRS official flagged administrability concerns Tuesday with potential safe harbors that would, in some cases, carve 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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October 08, 2024
Australia Makes Additional Changes To Tax Pro Conduct Code
After industry pushback, delays and further tweaks, Australia's minister for financial services signed into law Tuesday further amendments to the nation's tax professional code of conduct as part of the country's reaction to the PwC document leak scandal.
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October 08, 2024
Eversheds Recruits Tax Disputes Partner From RPC
Eversheds Sutherland announced it has added a regulatory and tax disputes partner to its London office from Reynolds Porter Chamberlain LLP.
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October 08, 2024
UK Gov't Should Impose Exit Tax, Economists Say
The U.K. should follow the example of Australia and Canada and enact a tax on business owners leaving the country, according to a report published Tuesday by a research group.
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October 08, 2024
EU Removes Antigua And Barbuda From Tax Blacklist
The Council of the European Union removed Antigua and Barbuda from its blacklist of noncooperation jurisdictions on global tax standards, the EU's Economic and Financial Affairs Council announced Tuesday.
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October 08, 2024
Gov't Urged To Commit To Pension Tax 'Lock' In Budget
The government must commit to a long-term pact on pension tax policy, experts said, warning that prolonged uncertainty is damaging consumer confidence.
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October 07, 2024
Justices Won't Hear Man's FBAR Constitutionality Challenge
The U.S. Supreme Court let stand Monday a Seventh Circuit decision dismissing a man's challenge to the constitutionality of the Bank Secrecy Act's requirement to report his foreign bank accounts, effectively ending the man's claim that the filings were an invasion of privacy.
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October 07, 2024
Jury Finds Professor Hid Foreign Bank Accounts
An 86-year-old former college professor faces more than $500,000 plus interest in penalties after a jury found that he had deliberately failed to report his foreign bank accounts in Switzerland and Turkey, according to documents filed in a California federal court.
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October 07, 2024
Man Who Faced Espionage Case Gets Probation Over Taxes
A Chinese engineer initially accused of illegally exporting documents on military aircraft to China was given probation and fined for failing to report about $1.4 million in business income by a Texas federal court after the government dropped its export charges.
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October 07, 2024
Singapore Seeks Comments On Min. Tax Safe Harbor Rules
Singapore is looking for feedback on proposed safe harbor and transition rules that would complement its coming implementation of the OECD's Pillar Two global minimum tax on large multinational corporations, its revenue authority said.
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October 07, 2024
Norway's Gov't Looking To Close Exit Tax Loophole
Norway's government said Monday that it is looking to close a loophole by adjusting its exit tax rules, though the tightening on when the tax must be paid would be paired with a 500% increase of the threshold for when the tax becomes applicable.
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October 07, 2024
Corp. Tactics May Call For Rethinking Tax Breaks, Paper Says
Countries may want to look at scaling back corporate tax breaks to address tax planning opportunities taken advantage of by businesses over the past 20 years while those tax breaks have proliferated, according to a working paper published Monday by the Organization for Economic Cooperation and Development.
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October 07, 2024
India Seeking Feedback On Income Tax Regime
India's government said Monday it is undergoing what it called a comprehensive review of its income tax regime in hopes of reducing litigation and increasing taxpayer certainty.
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October 07, 2024
TCJA Extension, Biz Tax Cut To Reward Top 5%, Report Says
Former President Donald Trump's planned extension of the 2017 tax cuts and lowering of corporate rates contribute most among his platform to lowering taxes for the wealthiest 5% and hiking them for everyone else, the left-leaning Institute on Taxation and Economic Policy said Monday in a report.
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October 05, 2024
Biz Owners Saved £1.3B On Inheritance Tax, Report Says
Business owners have saved their families an estimated £1.3 billion ($1.7 billion) last year by claiming business property relief on inheritance tax, according to law firm TWM Solicitors.
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October 04, 2024
DC Circ. Won't Reconsider Whistleblower's $690M Claim
The D.C. Circuit on Friday rejected a whistleblower's request that it rehear a ruling upholding the denial of up to $690 million, or 30%, of the $2.3 billion collected in an Internal Revenue Service offshore voluntary disclosure program.
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October 04, 2024
Promise Of OECD's Payments Tax Treaty Called Into Question
The OECD-designed tool to provide developing countries with better means to apply a minimum tax on income sent from their jurisdictions to low-taxed entities within a corporate group is inadequate to address those countries' revenue needs, tax policy organizations said.
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October 04, 2024
Australia Wants Feedback On Tax Promoter Penalty Regime
The Australian government asked Friday for feedback on the country's current tax promoter penalty regime as part of its efforts to strengthen its regulatory frameworks in the wake of the PwC document leak scandal.
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October 04, 2024
Europe Votes To Raise Tariffs On Electric Vehicles From China
European Union member states voted Friday to impose higher tariffs on imports of battery electric vehicles from China for the next five years, adding to the already staggering tariffs imposed by the United States and Canada.
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October 04, 2024
Brazil Establishes 15% Global Min. Tax On Large Cos.
Brazil's government has adopted the Organization for Economic Cooperation and Development's 15% global corporate minimum tax on large multinational corporations making €750 million ($823 million) annually.
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October 04, 2024
Former NJ Doctor Owes $4.8M In FBAR Penalties, Court Told
A former physician in New Jersey faces a tax bill of almost $5 million for failing to report 19 bank accounts he opened at Indian banks, the government told a federal court.
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October 04, 2024
ECJ Says Interest Deduction Limits Align With EU Law
Governments across the European Union can legislate to block businesses from getting corporate tax deductions on interest paid as part of noncommercial loans, the European Court of Justice ruled Friday.
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October 04, 2024
Taxation With Representation: Gibson Dunn, Weil, Simpson
In this week's Taxation with Representation, DirectTV buys EchoStar's video business for $10 billion, Marsh McLennan inks a $7.75 billion deal for McGriff Insurance, and PepsiCo closes a $1.2 billion deal to purchase Siete Foods.
Expert Analysis
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Don't Use The Same Template For Every Client Alert
As the old marketing adage goes, consistency is key, but law firm style guides need consistency that contemplates variety when it comes to client alert formats, allowing attorneys to tailor alerts to best fit the audience and subject matter, says Jessica Kaplan at Legally Penned.
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Think Like A Lawyer: Follow The Iron Rule Of Trial Logic
Many diligent and eager attorneys include every good fact, point and rule in their trial narratives — spurred by the gnawing fear they’ll be second-guessed for leaving something out — but this approach ignores a fundamental principle of successful trial lawyering, says Luke Andrews at Poole Huffman.
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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.