International

  • October 29, 2024

    Rimon Adds International Tax Expert In Philadelphia

    Rimon PC has added an expert in international tax and trusts and estates who joined the firm's Philadelphia office after working for his own practice.  

  • October 29, 2024

    Croatia, Australia Reach Double Tax Treaty Agreement

    Croatia and Australia have agreed on a treaty to avoid double taxation that will take effect when passed by the respective legislatures, the Croatian Ministry of Finance said.

  • October 29, 2024

    States Should Cede Profit-Shifting Fight To OECD, Atty Says

    States should shy away from using mandatory worldwide combined reporting to address profit shifting and instead allow the Organization for Economic Cooperation and Development to police tax avoidance from multinational corporations, a business trade group attorney said Tuesday.

  • October 29, 2024

    Switzerland Amends Double Tax Treaty With Kuwait

    Switzerland said Tuesday it has ratified changes to its double taxation treaty with Kuwait that are due to take effect early next year.

  • October 29, 2024

    US, Taiwan To Begin Talks On Double-Tax Agreement

    The U.S. and Taiwan announced Tuesday that they will begin a first round of negotiations to craft a double-tax avoidance agreement that would provide certain treaty-like benefits.

  • October 28, 2024

    Russia Says High Court Case May Help Nix $5B Award Suit

    Russia has told a D.C. federal court that a case recently accepted for review by the U.S. Supreme Court may provide it a path to argue that the court lacks jurisdiction to decide a case brought against the country by a Yukos Oil Co. unit.

  • October 28, 2024

    Latin America, Caribbean Must Up Tobacco Taxes, OECD Says

    Latin American and Caribbean countries must increase their tobacco excise tax levels, among other changes, to reduce the overall affordability of tobacco products to drive people to quit using them, the Organization for Economic Cooperation and Development said Monday.

  • October 28, 2024

    UK Construction Co. Due £3.2M In R&D Credits, Refunds

    A construction contractor is entitled to tax credits and refunds totaling over £3.2 million ($4.2 million) after the U.K.'s First-tier Tribunal ruled that its expenditures for research and development were not subsidized or contracted out by another party.

  • October 28, 2024

    European Commission Backs Simplified Minimum Tax Filing

    Multinational corporations could file returns for the 15% global minimum tax with a single country in the European Union that they would share with the others only where necessary under a proposal approved Monday by the bloc's executive branch, according to officials.

  • October 28, 2024

    Labour Budget Expected To Target Taxes At Biz, Investors

    The U.K. government is set to unveil its budget statement Wednesday after months of hinting at higher taxes, and experts say businesses and investors are bracing to bear the brunt of the possible tax changes, such as through increases to capital gains and payroll taxes.

  • October 28, 2024

    Chile Provides Guidance For Voluntary Disclosure Program

    Chile's tax agency provided guidance Monday for taxpayers interested in voluntarily disclosing their previously undeclared foreign assets in order to take advantage of a temporarily available tax rate.

  • October 28, 2024

    IRS Extends Relief For FATCA Filings Without ID Numbers

    Foreign financial institutions that report information on U.S. account holders to the Internal Revenue Service without including the taxpayer identification numbers associated with those accounts won't be flagged for noncompliance for the next three years, the agency said Monday.

  • October 28, 2024

    Wise Boss Hit With FCA Fine For Not Disclosing Tax Penalty

    The finance regulator said on Monday that it has fined the chief executive of a money transfer company £350,000 ($454,500) for his failure to tell the watchdog he had been penalized by HM Revenues and Customs for not paying his taxes.

  • October 28, 2024

    US Expatriations Tick Up In 3rd Quarter, IRS Says

    The number of people who expatriated from the U.S. rose during the third quarter of the year compared with the previous quarter, the Internal Revenue Service said Monday.

  • October 25, 2024

    German Drug Co. Due £21.5M VAT Refund, UK Tribunal Finds

    A German pharmaceutical provider is entitled to a refund of almost £21.5 million ($27.9 million) for the value-added tax it paid on the rebated portion of products supplied to the U.K.'s National Health Service, the British First-tier Tribunal ruled.

  • October 25, 2024

    Lebanon, Angola, Others Added To Financial Crime Watch List

    An intergovernmental task force on financial crimes added Lebanon, Angola, Algeria and the Ivory Coast to a watch list of countries with weak protections against money laundering and financing for armed groups, the group said Friday.

  • October 25, 2024

    Argentina Formally Shutters, Replaces Tax Agency

    Argentina's president formally dissolved the country's tax agency, the Federal Public Revenue Administration, and established a new agency, following through on an announcement two days earlier to end what he characterized as an oversize entity.

  • October 25, 2024

    Authorities Bust €113M VAT Fraud Ring Between Italy, China

    A sting carried out Friday by the European Public Prosecutor's Office busted a crime ring involving the import of clothing and accessories from China to Italy that hid the goods' origins in order to evade €113 million ($122 million) in value-added taxes, the EPPO said.

  • October 25, 2024

    Taxation With Representation: Davis Polk, Skadden, Kirkland

    In this week's Taxation With Representation, Atlantic Union Bankshares Corp. absorbs Sandy Spring Bancorp, Sophos and Secureworks merge, Wendel Group takes a stake in Monroe Capital LLC, and Acuity Brands Inc. buys QSC LLC.

  • October 25, 2024

    MVP: Wachtell's Tijana J. Dvornic

    Wachtell Lipton Rosen & Katz's Tijana J. Dvornic led the firm's tax team in representing Lumen Technologies in the largest liability management transaction outside of bankruptcy protections, including addressing over $15 billion of existing debt, earning her a spot as one of the 2024 Law360 Tax MVPs.

  • October 25, 2024

    Germany's Expected Tax Take For 5 Years Drops €58B

    Germany expects to raise €58.2 billion ($63 billion) less in revenue through 2028 than what was forecast in May, according to the country's finance minister, who said that the government allowing employers to pay tax-free bonuses caused uncertainties regarding income tax collections.

  • October 24, 2024

    IRS To End Automatic Foreign Gift Reporting Penalty

    Internal Revenue Service Commissioner Danny Werfel told the UCLA Tax Controversy Conference audience on Thursday that the agency will no longer automatically assess penalties for the late reporting of large foreign gifts, with the announcement eliciting applause from the audience of several hundred tax attorneys and tax professionals.

  • October 24, 2024

    IRS Forming Transfer Pricing Team To Aid Real-Time Audits

    The Internal Revenue Service is establishing a dedicated team to tackle transfer pricing issues that arise in real-time audits of companies participating in its compliance assurance process program, which should allow those issues to be handled more efficiently, an agency official said Thursday.

  • October 24, 2024

    Nigeria Frees Binance Exec Detained Over Money Laundering

    Nigeria's government released a top executive at cryptocurrency exchange Binance whom the government had been holding liable for money laundering charges against the company, the U.S. government and the exchange's CEO said Thursday.

  • October 24, 2024

    Wyden's Pharma Probe Could Build Case For Int'l Tax Reforms

    Senate Finance Committee Chairman Ron Wyden's investigation into the tax planning of major U.S. pharmaceutical companies could help fuel an effort to revamp U.S. international tax laws next year when Congress addresses expiring provisions of the Tax Cuts and Jobs Act.

Expert Analysis

  • This Election, We Need To Talk About Court Process

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    In recent decades, the U.S. Supreme Court has markedly transformed judicial processes — from summary judgment standards to notice pleadings — which has, in turn, affected individuals’ substantive rights, and we need to consider how the upcoming presidential election may continue this pattern, says Reuben Guttman at Guttman Buschner.

  • Mental Health First Aid: A Brief Primer For Attorneys

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    Amid a growing body of research finding that attorneys face higher rates of mental illness than the general population, firms should consider setting up mental health first aid training programs to help lawyers assess mental health challenges in their colleagues and intervene with compassion, say psychologists Shawn Healy and Tracey Meyers.

  • The Trade And Tax Issues Behind US-Canada Digital Tax Clash

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    The new Canadian digital services tax recently went into effect despite objections from the U.S., a controversy that represents an unusual mix of trade and tax policy, and many companies have been pondering how it will affect their e-commerce businesses, says Damon Pike at BDO.

  • Litigation Inspiration: Honoring Your Learned Profession

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    About 30,000 people who took the bar exam in July will learn they passed this fall, marking a fitting time for all attorneys to remember that they are members in a specialty club of learned professionals — and the more they can keep this in mind, the more benefits they will see, says Bennett Rawicki at Hilgers Graben.

  • AI May Limit Key Learning Opportunities For Young Attorneys

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    The thing that’s so powerful about artificial intelligence is also what’s most scary about it — its ability to detect patterns may curtail young attorneys’ chance to practice the lower-level work of managing cases, preventing them from ever honing the pattern recognition skills that undergird creative lawyering, says Sarah Murray at Trialcraft.

  • Ruling On Foreign Dividend Break Offers 2 Tax Court Insights

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    In Varian v. Commissioner, the U.S. Tax Court allowed a taxpayer's deduction for dividends from foreign subsidiaries, providing clarity on how the U.S. Supreme Court’s Loper Bright decision may affect challenges to Treasury regulations, and revealing a potential disallowance of foreign tax credits, say attorneys at Davis Polk.

  • Why Now Is The Time For Law Firms To Hire Lateral Partners

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    Partner and associate mobility data from the second quarter of this year suggest that there's never been a better time in recent years for law firms to hire lateral candidates, particularly experienced partners — though this necessitates an understanding of potential red flags, say Julie Henson and Greg Hamman at Decipher Investigative Intelligence.

  • Considering Possible PR Risks Of Certain Legal Tactics

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    Disney and American Airlines recently abandoned certain litigation tactics in two lawsuits after fierce public backlash, illustrating why corporate counsel should consider the reputational implications of any legal strategy and partner with their communications teams to preempt public relations concerns, says Chris Gidez at G7 Reputation Advisory.

  • It's No Longer Enough For Firms To Be Trusted Advisers

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    Amid fierce competition for business, the transactional “trusted adviser” paradigm from which most firms operate is no longer sufficient — they should instead aim to become trusted partners with their most valuable clients, says Stuart Maister at Strategic Narrative.

  • Navigating A Potpourri Of Possible Transparency Act Pitfalls

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    Despite the Financial Crimes Enforcement Network's continued release of guidance for complying with the Corporate Transparency Act, its interpretation remains in flux, making it important for companies to understand potentially problematic areas of ambiguity in the practical application of the law, say attorneys at Sidley.

  • How Methods Are Evolving In Textualist Interpretations

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    Textualists at the U.S. Supreme Court are increasingly considering new methods such as corpus linguistics and surveys to evaluate what a statute's text communicates to an ordinary reader, while lower courts even mull large language models like ChatGPT as supplements, says Kevin Tobia at Georgetown Law.

  • Why Attorneys Should Consider Community Leadership Roles

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    Volunteering and nonprofit board service are complementary to, but distinct from, traditional pro bono work, and taking on these community leadership roles can produce dividends for lawyers, their firms and the nonprofit causes they support, says Katie Beacham at Kilpatrick.

  • Firms Must Offer A Trifecta Of Services In Post-Chevron World

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    After the U.S. Supreme Court’s Loper Bright Enterprises v. Raimondo decision overturning Chevron deference, law firms will need to integrate litigation, lobbying and communications functions to keep up with the ramifications of the ruling and provide adequate counsel quickly, says Neil Hare at Dentons.

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