International
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July 17, 2024
Germany Sends Budget With €23B In Tax Cuts To Parliament
Germany's executive body approved a legislative package Wednesday that includes €23 billion ($25.2 billion) in tax cuts for citizens and companies across the next two years, sending it to the country's parliament for consideration.
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July 17, 2024
Disney To Join IBM's Bid To Bring NY Tax Fight To Justices
The Walt Disney Co. joined IBM in asking the U.S. Supreme Court for more time to file a petition for review of a New York high court decision that upheld tax on royalties received from foreign affiliates.
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July 17, 2024
Connell Foley Adds Wilson Elser Tax Pro In Group Upgrade
Connell Foley LLP strengthened its tax and estate team this week with the promotion of several attorneys up to partner and the addition of a mergers and acquisitions and corporate restructuring tax expert previously of counsel at Wilson Elser Moskowitz Edelman & Dicker LLP.
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July 17, 2024
2 Arrested In €7.6M Italian VAT Fraud Scheme
Financial police in Italy arrested who authorities said were two main suspects in a scheme involving sales of luxury cars that evaded €7.6 million ($8.3 million) in value-added taxes, the European Public Prosecutor's Office said Wednesday.
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July 17, 2024
IRS Plans August Hearing On Stock Buyback Tax Rules
The Internal Revenue Service will hold a public hearing Aug. 27 on proposed regulations governing a new excise tax on repurchases of corporate stock, the agency said Wednesday.
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July 17, 2024
Treasury Finalizes Rules To Target 'Killer B' Transactions
The U.S. Treasury Department published final regulations Wednesday aimed at so-called Killer B transactions, which involve certain corporate reorganizations with at least one foreign affiliate that ultimately allow U.S. companies to avoid domestic taxes.
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July 17, 2024
Rising Star: Cravath's Kiran Sheffrin
Kiran Sheffrin of Cravath Swaine & Moore LLP has advised companies from Anheuser-Busch InBev to Valvoline on multibillion-dollar deals, including a $50 billion combination resulting in the formation of pharmaceutical giant Viatris, earning her a spot among the tax law practitioners under age 40 honored by Law360 as Rising Stars.
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July 17, 2024
Woman Can't Escape Suit Over Partner's $1.1M FBAR Debt
A woman whose late romantic partner owed $1.1 million in reporting penalties on hidden financial accounts in France and Switzerland can't stop the government from pursuing a suit against her for half the value of her home, a New York federal court ruled.
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July 17, 2024
Baker McKenzie Adds EY Partner To Mexico City Office
Baker McKenzie has appointed a new partner from EY Mexico to its North American tax practice group in Mexico City.
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July 17, 2024
Estonia Expects Solutions From EU Chair On VAT Law
Estonia said Wednesday that it expects "constructive solutions" from the current chair of European Union meetings regarding changes to value-added tax law, which Estonia blocked during meetings of EU finance ministers in May and June.
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July 17, 2024
Labour Gov't To Make Fiscal Rules Law, Empower OBR
The new Labour government will legislate to write into law the Treasury's long-held fiscal rules and grant new powers to the Office for Budget Responsibility to scrutinize policy, according to plans confirmed in the King's Speech on Wednesday.
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July 16, 2024
Intracompany Prices Should Reflect Acquired IP, Panelists Say
When one company buys another for its intellectual property, the subsequent pricing of that asset between the now-related entities should reflect the value of what was acquired, transfer pricing specialists said Tuesday at a conference in Washington, D.C.
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July 16, 2024
More Geographic Adjustments 'On The Table' For Amount B
Countries' ability to make further adjustments for geographic differences in the streamlined transfer pricing approach known as Amount B — part of the OECD's plan for reallocating taxing rights among jurisdictions — is "still on the table," an official from the organization said Tuesday.
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July 16, 2024
Va. Tax Head Nixes Assessment On Man For Work In India
A Virginia man was wrongly assessed income tax for services he conducted while living in India, the state's tax commissioner said in a letter ruling published Tuesday.
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July 16, 2024
Tax Transparency Neglected In Latin America, Ex-Officials Say
The international tax transparency system is failing to produce results for Latin American governments, whose scant information requests are too often met with resistance and whose prosecutions generally lack a cross-cutting approach to tax, former officials from the region said Tuesday.
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July 16, 2024
DC Circ. Upholds Dismissal Of Tax Whistleblower Award Case
The D.C. Circuit upheld Tuesday the U.S. Tax Court's dismissal of a Mississippi man's case seeking review of the denial of his whistleblower claim for 30% of the revenue collected by an Internal Revenue Service offshore voluntary disclosure program.
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July 16, 2024
EU Opposed Fast-Tracking Reforms Under UN Tax Convention
The European Union is concerned that a majority of countries want to create early protocols simultaneously with a United Nations framework convention on international tax cooperation, according to a statement endorsed Tuesday by the bloc's finance ministers.
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July 16, 2024
Australian Tax Pros Push Back On Updated Code Of Conduct
Ten groups representing tax professionals in Australia said the government should reconsider newly passed changes to the country's code of conduct for tax agent services, saying the rules have created inconsistencies and uncertainties.
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July 16, 2024
Rising Star: Skadden's Melinda Gammello
Melinda Gammello of Skadden Arps Slate Meagher & Flom LLP has advised numerous clients before the U.S. Tax Court and elsewhere on complex tax matters, including transfer pricing issues and the treatment of financial transactions within a company, earning her a spot among the tax law practitioners under 40 honored by Law360 as Rising Stars.
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July 16, 2024
The 2024 Diversity Snapshot: What You Need To Know
Law firms' ongoing initiatives to address diversity challenges have driven another year of progress, with the representation of minority attorneys continuing to improve across the board, albeit at a slower pace than in previous years. Here's our data dive into minority representation at law firms in 2023.
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July 16, 2024
These Firms Have The Most Diverse Equity Partnerships
Law360’s law firm survey shows that firms' efforts to diversify their equity partner ranks are lagging. But some have embraced a broader talent pool at the equity partner level. Here are the ones that stood out.
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July 16, 2024
Turkish Parliament Considering Global Minimum Tax
Turkey's Parliament is considering implementing the Organization for Economic Cooperation and Development's 15% global minimum tax on some large multinational corporations alongside other tax changes, according to news reports Tuesday.
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July 16, 2024
3 Tax Reg Groups That May Be Shaky After High Court Rulings
The U.S. Supreme Court issued two rulings that, when combined, open up long-standing federal regulations to challenges without judicial deference to agencies — a pairing that could weaken several categories of tax rules, including guidance issued under the 2017 federal overhaul. Here, Law360 looks at three batches of tax regulations that may be vulnerable in the aftermath of the high court's decisions.
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July 16, 2024
Labour Government Urged To Introduce Green Tax Credits
The new Labour government should introduce tax credits for businesses investing in green energy technology, according to a tax expert from the Confederation of British Industry.
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July 16, 2024
EU Leader Stresses Importance Of Digital VAT Law
The head of the European Union's council of members stressed on Tuesday the importance of an agreement on a change to EU VAT law that was blocked by one member country in consecutive meetings in May and June.
Expert Analysis
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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.
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Former Minn. Chief Justice Instructs On Writing Better Briefs
Former Minnesota Supreme Court Chief Justice Lorie Gildea, now at Greenberg Traurig, offers strategies on writing more effective appellate briefs from her time on the bench.
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Stay Interviews Are Key To Retaining Legal Talent
Even as the economy shifts and layoffs continue, law firms still want to retain their top attorneys, and so-called stay interviews — informal conversations with employees to identify potential issues before they lead to turnover — can be a crucial tool for improving retention and morale, say Tina Cohen Nicol and Kate Reder Sheikh at Major Lindsey.
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Neb. Justices Should Weigh IRC Terms In Dividend Tax Case
Nebraska’s highest court, which will hear oral arguments in Precision CastParts v. Department of Revenue on April 1, should recognize that the Internal Revenue Code provides key clues to defining “dividends received or deemed to be received,” and therefore limits Nebraska’s tax on foreign-sourced corporate income, says Joseph Schmidt at Ryan.
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Judicial Independence Is Imperative This Election Year
As the next election nears, the judges involved in the upcoming trials against former President Donald Trump increasingly face political pressures and threats of violence — revealing the urgent need to safeguard judicial independence and uphold the rule of law, says Benes Aldana at the National Judicial College.
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Spartan Arbitration Tactics Against Well-Funded Opponents
Like the ancient Spartans who held off a numerically superior Persian army at the Battle of Thermopylae, trial attorneys and clients faced with arbitration against an opponent with a bigger war chest can take a strategic approach to create a pass to victory, say Kostas Katsiris and Benjamin Argyle at Venable.
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What Recent Study Shows About AI's Promise For Legal Tasks
Amid both skepticism and excitement about the promise of generative artificial intelligence in legal contexts, the first randomized controlled trial studying its impact on basic lawyering tasks shows mixed but promising results, and underscores the need for attorneys to proactively engage with AI, says Daniel Schwarcz at University of Minnesota Law School.
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How FinCEN Proposal Expands RE Transaction Obligations
Against a regulatory backdrop foreshadowing anti-money laundering efforts in the real estate sector, the Financial Crimes Enforcement Network's proposed rule significantly expands reporting requirements for certain nonfinanced residential real estate transfers and necessitates careful review, say attorneys at Fried Frank.
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Litigation Inspiration: A Source Of Untapped Fulfillment
As increasing numbers of attorneys struggle with stress and mental health issues, business litigators can find protection against burnout by remembering their important role in society — because fulfillment in one’s work isn’t just reserved for public interest lawyers, say Bennett Rawicki and Peter Bigelow at Hilgers Graben.