International
-
September 23, 2024
The Tax Angle: Corporate Inversions, SALT Cap
From a look at criticisms that the 2017 federal tax law failed to stop corporations from moving overseas to GOP efforts to navigate the SALT cap ahead of the November elections, here's a peek into a reporter's notebook on a few of the week's developing tax stories.
-
September 23, 2024
Sysco Allowed $324M Dividend Deduction After Varian Ruling
Sysco Corp. can deduct $324 million in foreign dividends after agreeing with the Internal Revenue Service that a decision in a similar case brought by Varian Medical Systems resolved their dispute, the U.S. Tax Court said in an order.
-
September 23, 2024
Disney Asks Justices To Review NY Tax On Foreign Royalties
New York's highest court used the wrong standard for evaluating tax statutes for discrimination when it denied deductions that The Walt Disney Co. sought for royalties received from foreign affiliates, the company argued in a petition to the U.S. Supreme Court that Law360 obtained Monday.
-
September 23, 2024
Singapore Man Sentenced To 4 Years In $43M Fraud Scheme
A Singapore man involved in a scheme that made SG$55 million ($43 million) in fictitious sales that resulted in more than SG$7.5 million in fraudulent goods-and-services tax, or GST, refund claims was sentenced to more than four years in prison Monday, the country's revenue authority said.
-
September 23, 2024
IRS Finalizing Pricing Pact Guidance, Official Says
The Internal Revenue Service is in the final stages of updating revenue procedures to help multinational corporations pursue advance pricing agreements and resolve tax treaty disputes, and it will release the guidance soon, an agency official said Monday.
-
September 23, 2024
Irish Carbon Tax Could Generate €8.8B By 2030, Report Says
Planned rate increases and other factors could see Ireland's carbon tax generate at least €8.8 billion ($9.8 billion) in revenue over the next six years, compared with over €3.3 billion generated from 2019 through 2023, the country's Financial Services Division said.
-
September 23, 2024
Squire Patton Tax Ace Joins Winston & Strawn In Dallas
Winston & Strawn LLP announced Monday it has expanded its tax offerings with the addition of an experienced attorney from Squire Patton Boggs LLP in Texas.
-
September 23, 2024
HMRC Raises £1B Cracking Down On Tax Fraud
HM Revenue & Customs raised almost £1 billion ($1.3 billion) in its most serious criminal investigations of tax fraud year-on-year in April, according to research published by a law firm Monday.
-
September 23, 2024
Belgium Has High Tax Burden, Public Debt, OECD Says
While there are some tax changes Belgium should consider, the country should tackle its high public debt through better spending practices because its tax burden is among the highest in the OECD, the organization said Monday.
-
September 23, 2024
Pension Experts Urge Tax Breaks For UK Investment Plan
The government could best encourage investment in the economy from pension schemes by adopting tax incentives, a trade body said.
-
September 20, 2024
8th Circ. To Hear Args In 3M's $24M Tax Case Next Month
The Eighth Circuit said Friday that it will hear oral arguments next month in 3M's transfer pricing appeal, in which the multinational conglomerate is challenging the Internal Revenue Service's authority to reallocate to the company $24 million from a Brazilian affiliate.
-
September 20, 2024
IRS Special Trial Attorney Joins Hochman Salkin In California
When Hochman Salkin Toscher Perez PC's newest principal, Sebastian Voth, was studying at Emory University School of Law, a former chief counsel for the Internal Revenue Service told students that the IRS was a great place to start their careers. After 15 years as an IRS attorney, Voth found that the agency was also a great place to work, he told Law360 Pulse in an interview Friday.
-
September 20, 2024
Australia Seeks Comments On Luxury Car Tax Green Changes
Australia is looking for comments on plans to adjust the country's luxury car tax to update the definition of a fuel-efficient car and to make changes to the way the tax threshold is indexed, the country's Treasury Department said Friday.
-
September 20, 2024
Hong Kong's Tax Revenue Drops For 2nd Straight Year
Hong Kong's tax revenue dipped by HK$14 billion ($1.8 billion) to HK$342 billion in the 2023-24 tax year — the second straight year with a drop — largely because of decreases in stamp duty and profit tax collections, its tax authority said Friday.
-
September 20, 2024
Taxation With Representation: Gibson Dunn, Holland & Knight
In this week's Taxation With Representation, CACI International buys Azure Summit Technology, Hotel Engine lands a valuation led by Permira, and Knowles Corp. sells its microphone business to Syntiant Corp.
-
September 20, 2024
UK Budget May Seek Gains From Inheritance Tax, Firms Say
The U.K. government may try to squeeze more revenue out of the wealthy via inheritance tax, wealth management firms said Friday following the release of data showing the levy is generating higher returns for HM Treasury.
-
September 19, 2024
Pillar 1's Safe Harbor Limits Split Of Taxing Rights, Study Says
The redistribution of corporate taxing rights among countries that agreed to new profit reallocation rules known as Pillar One would be "seriously affected" by a proposed safe harbor, according to report from a think tank funded by the European Union.
-
September 19, 2024
Death Doesn't Preclude FBAR Penalties, Judge Says
The death of a U.S. citizen who failed to file reports of foreign bank and financial accounts doesn't stop the U.S. government from enforcing penalties against his estate, a New York federal judge ruled.
-
September 19, 2024
Spain Tax Inspections Generated €16.7B In Revenue In 2023
Spain's tax agency said Thursday that it increased the number of control actions it took against large companies and other groups by nearly 14% in 2023 as part of the agency's €16.7 billion ($18.6 billion) in revenue generated from control work last year.
-
September 19, 2024
Sweden Aiming For Broad Tax Cuts In 2025 Budget
Swedish taxpayers would see lower tax rates in many areas, such as on their labor and pensions, as part of a proposed 2025 budget that the government sent to the country's legislature for consideration Thursday.
-
September 19, 2024
EU, China Fail To End EV Dispute But Talks Continue
Negotiators from the European Union and China failed to resolve a dispute over EU antisubsidy tariffs on imported electric vehicles from China but promised Thursday to intensify efforts to find a mutually agreeable solution.
-
September 19, 2024
Nine Countries Sign Treaty For OECD Min. Tax On Payments
Indonesia, Turkey, Congo and six other countries signed a multilateral treaty aimed at implementing a 9% minimum tax on income sent from their jurisdictions to low-taxed entities within a corporate group, the OECD said Thursday.
-
September 19, 2024
EU Top Court Rules UK's CFC Tax Breaks Not State Aid
The European Court of Justice ruled Thursday that tax breaks the U.K. gave to certain companies under controlled foreign company regulations did not breach European Union state aid law.
-
September 19, 2024
Apple Ruling Prompts EU Lawmakers To Call For Tax Justice
Citing the recent European court judgment requiring Apple to pay €13 billion ($14.5 billion) in taxes to Ireland, European Union lawmakers demanded Thursday that the fight against tax evasion and for corporate tax harmonization be stepped up.
-
September 19, 2024
EU Wrong To Block Berlusconi's Bank Stake, Top Court Rules
Europe's highest court ruled Thursday that the European Central Bank was wrong to decide that a prior conviction for tax fraud prevented former Italian Prime Minister Silvio Berlusconi from holding a stake in a bank in the country.
Expert Analysis
-
4 Legal Ethics Considerations For The New Year
As attorneys and clients reset for a new year, now is a good time to take a step back and review some core ethical issues that attorneys should keep front of mind in 2024, including approaching generative artificial intelligence with caution and care, and avoiding pitfalls in outside counsel guidelines, say attorneys at HWG.
-
What The Law Firm Of The Future Will Look Like
As the legal landscape shifts, it’s become increasingly clear that the BigLaw business model must adapt in four key ways to remain viable, from fostering workplace flexibility to embracing technology, say Kevin Henderson and Eric Pacifici at SMB Law Group.
-
4 PR Pointers When Your Case Is In The News
Media coverage of new lawsuits exploded last year, demonstrating why defense attorneys should devise a public relations plan that complements their legal strategy, incorporating several objectives to balance ethical obligations and advocacy, say Nathan Burchfiel at Pinkston and Ryan June at Castañeda + Heidelman.
-
Unpacking The Proposed Production Tax Credit Regulations
Recently proposed tax regulations for claiming the U.S. clean-energy manufacturers' production credit under Internal Revenue Code Section 45X are less stringent than many had feared but fail to define a fundamental eligibility requirement, say Casey August and Jared Sanders at Morgan Lewis.
-
10 Considerations For Litigating A New York Tax Case
While some of New York’s recently adopted corporate tax regulations are likely to face legal challenges, aggrieved taxpayers should answer certain questions before deciding to embark on the tax litigation process, say Cyavash Ahmadi and Jeffrey Friedman at Eversheds Sutherland.
-
Law Firm Strategies For Successfully Navigating 2024 Trends
Though law firms face the dual challenge of external and internal pressures as they enter 2024, firms willing to pivot will be able to stand out by adapting to stakeholder needs and reimagining their infrastructure, says Shireen Hilal at Maior Consultants.
-
Attorneys' Busiest Times Can Be Business Opportunities
Attorneys who resolve to grow their revenue and client base in 2024 should be careful not to abandon their goals when they get too busy with client work, because these periods of zero bandwidth can actually be a catalyst for future growth, says Amy Drysdale at Alchemy Consulting.
-
How Attorneys Can Be More Efficient This Holiday Season
Attorneys should consider a few key tips to speed up their work during the holidays so they can join the festivities — from streamlining the document review process to creating similar folder structures, says Bennett Rawicki at Hilgers Graben.
-
How Clients May Use AI To Monitor Attorneys
Excerpt from Practical Guidance
Artificial intelligence tools will increasingly enable clients to monitor and evaluate their counsel’s activities, so attorneys must clearly define the terms of engagement and likewise take advantage of the efficiencies offered by AI, says Ronald Levine at Herrick Feinstein.
-
The Pop Culture Docket: Judge D'Emic On Moby Grape
The 1968 Moby Grape song "Murder in My Heart for the Judge" tells the tale of a fictional defendant treated with scorn by the judge, illustrating how much the legal system has evolved in the past 50 years, largely due to problem-solving courts and the principles of procedural justice, says Kings County Supreme Court Administrative Judge Matthew D'Emic.
-
Breaking Down High Court's New Code Of Conduct
The U.S. Supreme Court recently adopted its first-ever code of conduct, and counsel will need to work closely with clients in navigating its provisions, from gift-giving to recusal bids, say Phillip Gordon and Mateo Forero at Holtzman Vogel.
-
Legal Profession Gender Parity Requires Equal Parental Leave
To truly foster equity in the legal profession and to promote attorney retention, workplaces need to better support all parents, regardless of gender — starting by offering equal and robust parental leave to both birthing and non-birthing parents, says Ali Spindler at Irwin Fritchie.
-
A Year-End Look At Florida's Capital Investment Tax Credit
Notwithstanding the Walt Disney Co.’s feud with Gov. Ron DeSantis this year, Florida's capital investment tax credit will continue to make the state a favored destination for large corporations, particularly in light of the new federal alternative minimum tax and the Pillar Two top-up tax, says Alan Lederman at Gunster.