International
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November 22, 2024
Isle Of Man Parliament Passes OECD's Global Minimum Tax
The Isle of Man's Parliament approved a bill implementing two portions of the Organization for Economic Cooperation and Development's 15% global minimum tax on large multinational entities making at least €750 million ($781 million) annually, starting in 2025.
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November 22, 2024
IRS Ignores Text In $248M Fight, Liberty Global Tells 10th Circ.
The Internal Revenue Service is incorrectly applying the U.S. tax code in denying Liberty Global's claim for $248 million in foreign tax credits tied to its sale of a Japanese affiliate, the telecommunications company told the Tenth Circuit.
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November 22, 2024
Halliburton Omitted Grounds From $35M Refund Suit, US Says
A Texas federal court must dismiss parts of Halliburton's $35 million tax refund lawsuit because the company failed to raise two grounds of relief in its administrative claim for a refund, the U.S. argued.
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November 22, 2024
Taxation With Representation: Stradley Ronon, Davis Polk
In this week's Taxation With Representation, Amcor PLC buys Berry Global Group Inc., AeroVironment buys BlueHalo, Robinhood Markets Inc. acquires TradePMR, and Comcast Corp. spins off a suite of NBCUniversal cable television networks.
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November 22, 2024
2 Convicted In €3.7M EU VAT Fraud Scheme
A German court convicted two people for their roles in a value-added tax fraud scheme involving small electronic goods that caused an estimated €3.7 million ($3.86 million) in lost tax revenue, the European Public Prosecutor's Office said.
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November 22, 2024
Spain Raises Bank Windfall Levy, Enacts Minimum Tax
The Spanish government is set to increase its windfall tax on banks with more than €5 billion ($5.2 billion) in income as well as implement a minimum corporate tax on multinational companies following a vote by lawmakers.
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November 21, 2024
Australia Floats Paths For Adopting Crypto Disclosure Rules
The Australian government floated two options Thursday for implementing a global crypto-asset reporting framework: adopt a standardized model or take a "bespoke approach" that would offer more flexibility but may also increase compliance costs.
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November 21, 2024
Breach Of VAT Rules Can Block €385K Refund, ECJ Rules
Bulgarian tax authorities can deny a value-added tax refund of approximately €385,000 ($403,000) to a domestic company that did not have the tax itemized on invoices, the European Court of Justice ruled Thursday.
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November 21, 2024
6 Nations Must Improve Transparency Framework, OECD Says
Six countries that have generally complied with global standards for exchanging financial information for tax purposes could nevertheless improve their mechanisms for accessing data about entity owners, according to reports released Thursday by the Organization for Economic Cooperation and Development.
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November 21, 2024
VAT Stays King Of Consumption Taxes Across OECD
Value-added tax revenue continued to be the largest category of consumption taxes across the Organization for Economic Cooperation and Development in 2022, it said Thursday, generating an average of 20.8% of total revenue in 2022, a 0.1 percentage point increase.
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November 21, 2024
Tax Revenue Ratio Remained Steady In 2023, OECD Says
The average tax-to-gross domestic product ratio across Organization for Economic Cooperation and Development countries remained relatively steady in 2023 compared with the year prior, the OECD said Thursday, even as they deal with challenges such as the increasing cost of living and climate change.
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November 21, 2024
Israel-Hamas War Tax Relief Needed More Notice, TIGTA Says
While the Internal Revenue Service did well to proactively identify taxpayers likely affected by the Israel-Hamas war that it sought to grant tax relief, it failed to directly notify these taxpayers, the Treasury Inspector General for Tax Administration said Thursday.
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November 21, 2024
11th Circ. Asked To Rethink $100M Credit For John Hancock
The Eleventh Circuit should reverse its decision allowing John Hancock Life Insurance Co. to keep $100 million in foreign tax credits that rightfully belong to the company's investors, trustees of a retirement plan said in arguing that the court overlooked a key U.S. Treasury regulation.
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November 21, 2024
Ryanair Threatens To Cut France Flights Over Ticket Tax
Irish budget airline Ryanair warned it would suspend flights to and from 10 regional airports in France if the country goes through with its proposed tax on plane tickets, which would take effect in January.
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November 20, 2024
NY Says Changes To Fed. Tax Return Reset Refund Timeline
A couple living in Switzerland for part of each year timely filed their claim for overpaid New York state income taxes dating back to 2011 soon after winning double-taxation relief under the Swiss-U.S. tax treaty in 2018, the state's tax department said.
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November 20, 2024
NY Tax Withholding Not Needed For Foreign Board Member
A New York company that appointed an Italian citizen to its board of directors does not have to withhold state income tax for payments made to that board member, the state's tax department said.
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November 20, 2024
Irish Social Democrats Run On Wealth Tax For Millionaires
Ireland's Social Democrats are campaigning for this month's general election on a 0.5% tax on individuals' assets over €1 million ($1.1 million) — excluding homes, family businesses, art and pensions — and 1% for assets over €2 million, according to its manifesto.
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November 20, 2024
Israel Commits To OECD Crypto Information Swap Framework
Israel committed to implementing the Organization for Economic Cooperation and Development's framework for automatically exchanging financial information regarding crypto-assets by 2027, the country's Ministry of Finance said Wednesday.
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November 20, 2024
UK Biz Owes Taxes On £200M Sale Of Lease, Court Affirms
A U.K. property company owes tax on its intragroup purchase of a lease for a 50-story apartment tower in central London for £200 million ($253 million) despite its tax advisers' promise of a tax-free step-up in basis, the Upper Tribunal said Wednesday.
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November 20, 2024
Feds Again Seek Early Win In $11.6M Willful FBAR Dispute
The U.S. government intends to renew its request to resolve a narrow matter in a dispute with an international businessman facing an $11.6 million penalty for willful failure to report his foreign bank accounts before the case heads to trial, according to a filing in Hawaii federal court.
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November 20, 2024
Data Centers Ineligible For Tax Breaks, UK Justices Affirm
The U.K. Supreme Court dismissed a British developer's appeal Wednesday, ruling that HM Revenue & Customs was right to deny the company tax allowances it claimed on building two data centers in an enterprise zone.
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November 20, 2024
Switzerland To Expand Pillar 2 Minimum Tax Legislation
The Swiss government announced Wednesday that it is expanding its legislation under an international minimum tax agreement known as Pillar Two to add a measure that will help bring in up to 3.5 billion Swiss francs ($4 billion).
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November 20, 2024
NY Resident Owes Tax On Bonuses For Work Out Of State
A New York resident who lived out of the country until late 2018 owes state and New York City tax on bonuses and stock units that were paid in 2019 for work done in prior years, the state tax agency said.
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November 19, 2024
Turkish Tax Inspectors Target Alcohol Cos. For Evasion
Turkish tax inspectors raided 100 addresses tied to alcohol businesses as part of an ongoing crackdown against suspected tax evasion by companies with 100 billion lira ($2.9 billion) in combined revenue, Turkey's Ministry of Treasury and Finance told state news media.
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November 19, 2024
G20 To Cooperate On Soft Law For Taxing Ultra-Wealthy
Leaders of the world's largest economies intend to cooperate on taxing "ultra-high-net-worth individuals" through soft law approaches such as exchanging best practices and creating model policies that address tax avoidance, according to a Group of 20 Nations declaration.
EU Official Says GILTI Changes Could Nullify Pillar 2 Backstop
The U.S. has an opportunity to shield multinationals from the Pillar Two 15% global minimum tax backstop rule in other jurisdictions by revising its tax on global intangible low-taxed income next year, a European Union tax official said Thursday.
India's Top Court Allows Tax Credits For Excise Duties Paid
Excise duties that India's mobile telecommunication providers pay when building the infrastructure for their networks — such as transmission towers — can be used as tax credits, the Supreme Court of India ruled Wednesday.
Liberty Global Tax Break Based On Void Moves, 10th Circ. Told
The economic substance doctrine is broad and can invalidate telecommunications company Liberty Global's transaction that led to a $2.4 billion deduction because steps taken to maximize the tax break lacked business purpose, a government attorney told the Tenth Circuit on Tuesday.
EU Official Says GILTI Changes Could Nullify Pillar 2 Backstop
The U.S. has an opportunity to shield multinationals from the Pillar Two 15% global minimum tax backstop rule in other jurisdictions by revising its tax on global intangible low-taxed income next year, a European Union tax official said Thursday.
India's Top Court Allows Tax Credits For Excise Duties Paid
Excise duties that India's mobile telecommunication providers pay when building the infrastructure for their networks — such as transmission towers — can be used as tax credits, the Supreme Court of India ruled Wednesday.
Liberty Global Tax Break Based On Void Moves, 10th Circ. Told
The economic substance doctrine is broad and can invalidate telecommunications company Liberty Global's transaction that led to a $2.4 billion deduction because steps taken to maximize the tax break lacked business purpose, a government attorney told the Tenth Circuit on Tuesday.
Featured Stories
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Countries Eye Certain Tax Credits To Get Leg Up Under Pillar 2
The international minimum tax agreement known as Pillar Two is changing how countries compete for corporate investment, in part by prompting some governments to retool their tax credit systems in ways that could edge out jurisdictions with fewer resources.
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The Tax Angle: TCJA Debate, S Corp. Compliance
From a look at congressional lawmakers ramping up their debate over the expiration of the GOP's 2017 tax overhaul law to the IRS' plans to provide more oversight for pass-through businesses and S corporations, here's a peek into a reporter's notebook on a few of the week's developing tax stories.
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Trump, GOP Victories May Imperil OECD Global Tax Plan
President-elect Donald Trump's and Republicans' victories in the U.S. elections this month call into question whether the OECD's two-pillar global tax plan can be effectively implemented and whether the plan's minimum tax backstop rule can be applied amid threats of retaliatory tax measures by the U.S.
Expert Analysis
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3 Ways To Train Junior Lawyers In 30 Minutes Or Less
Today’s junior lawyers are experiencing a skills gap due to pandemic-era disruptions, but firms can help bring them up to speed by offering high-impact skill building content in bite-sized, interactive training sessions, say Stacey Schwartz at Katten, Diane Costigan at Winston & Strawn and Lauren Tierney at Freshfields.
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The Bar Needs More Clarity On The Discovery Objection Rule
Almost 10 years after Federal Rule of Civil Procedure 34 was amended, attorneys still seem confused about what they should include in objections to discovery requests, and until the rules committee provides additional clarity, practitioners must beware the steep costs of noncompliance, says Tristan Ellis at Shanies Law Office.
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So You Want To Move Your Law Practice To Canada, Eh?
Google searches for how to move to Canada have surged in the wake of the U.S. presidential election, and if you’re an attorney considering a move to the Great White North, you’ll need to understand how the practice of law differs across the border, says David Postel at Henein Hutchison.
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Promoting Diversity In The Selection Of ADR Neutrals
Excerpt from Practical Guidance
Choosing neutrals from diverse backgrounds is an important step in promoting inclusion in the legal profession, and it can enhance the legitimacy and public perception of alternative dispute resolution proceedings, say attorneys at Lowenstein Sandler.
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Striking A Balance Between AI Use And Attorney Well-Being
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As the legal industry increasingly adopts generative artificial intelligence tools to boost efficiency, leaders must note the hidden costs of increased productivity, and work to protect attorneys’ well-being while unlocking AI’s full potential, says Ed Sohn at Factor.
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How Judiciary Can Minimize AI Risks In Secondary Sources
Because courts’ standing orders on generative artificial intelligence and other safeguards do not address the risk of hallucinations in secondary source materials, the judiciary should consider enlisting legal publishers and database hosts to protect against AI-generated inaccuracies, say attorneys at Lankler Siffert & Wohl.
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How Attorneys Can Break Free From Career Enmeshment
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Ambitious attorneys can sometimes experience career enmeshment — when your sense of self-worth becomes unhealthily tangled up in your legal vocation — but taking the time to discover and realign with your core personal values can help you recover your identity, says Janna Koretz at Azimuth Psychological.
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Lawyers With Disabilities Are Seeking Equity, Not Pity
Attorneys living with disabilities face extra challenges — including the need for special accommodations, the fear of stigmatization and the risk of being tokenized — but if given equitable opportunities, they can still rise to the top of their field, says Kate Reder Sheikh, a former attorney and legal recruiter at Major Lindsey & Africa.
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Judicial Committee Best Venue For Litigation Funding Rules
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The Advisory Committee on Civil Rules' recent decision to consider developing a rule for litigation funding disclosure is a welcome development, ensuring that the result will be the product of a thorough, inclusive and deliberative process that appropriately balances all interests, says Stewart Ackerly at Statera Capital.
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The Strategic Advantages Of Appointing A Law Firm CEO
The impact on law firms of the recent CrowdStrike outage underscores that the business of law is no longer merely about providing supplemental support for legal practice — and helps explain why some law firms are appointing dedicated, full-time CEOs to navigate the challenges of the modern legal landscape, says Jennifer Johnson at Calibrate Strategies.
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How Cos. Can Build A Strong In-House Pro Bono Program
During this year’s pro bono celebration week, companies should consider some key pointers to grow and maintain a vibrant in-house program for attorneys to provide free legal services for the public good, says Mary Benton at Alston & Bird.
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Home Canning Makes Me A Better Lawyer
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Making my own pickles and jams requires seeing a process through from start to finish, as does representing clients from the start of a dispute at the Patent Trial and Appeal Board through any appeals to the Federal Circuit, says attorney Kevin McNish.
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Use The Right Kind Of Feedback To Help Gen Z Attorneys
Generation Z associates bring unique perspectives and expectations to the workplace, so it’s imperative that supervising attorneys adapt their feedback approach in order to help young lawyers learn and grow — which is good for law firms, too, says Rachael Bosch at Fringe Professional Development.