International

  • February 25, 2025

    Brazil Starts Corp. Tax Compliance Benefit Program

    Companies in Brazil that are up to date and compliant with their tax obligations will be offered benefits for doing so as part of a pilot program, the country's tax service said.

  • February 24, 2025

    Eaton's Foreign Tax Credits Rejected By Tax Court

    The U.S. Tax Court rejected foreign tax credits that Eaton Corp. had claimed on its lower-tier overseas entities' income taxes for 2007 and 2008, saying in a Monday opinion that its overseas ownership structure had disqualified the multinational power management company.

  • February 24, 2025

    Investor Settles In $2.1B Danish Tax Fraud Case

    A U.S. investor who was among those accused by Denmark's tax agency of participating in a $2.1 billion tax fraud scheme related to fraudulently claiming refunds on tax withheld from stock dividends has reached a settlement, according to New York federal court documents filed Monday.

  • February 24, 2025

    Denmark Argues Misrepresentation Led To £1.4B Tax Refunds

    Denmark's tax authority told the High Court of Justice on Monday that it would not have paid out billions in refunds to a British trader and others accused of involvement in a fraudulent trading scheme had they not submitted forms purporting to show eligibility for tax refunds.

  • February 24, 2025

    Ex-Goldman Exec Owes For Not Filing FBARs, US Says

    A former Goldman Sachs banking executive who lives in Australia owes penalties to the Internal Revenue Service for failing to report foreign bank accounts she held, the U.S. government told a D.C. federal court.

  • February 24, 2025

    NZ Reviewing Charity Business Income Tax Exemption

    New Zealand is looking for comments on its internationally unique tax structure that allows charities and not-for-profits to conduct business activities tax-free in order to raise money, asking stakeholders whether such a regime continues to be effective, the country's tax agency said Monday.

  • February 24, 2025

    Apple To Invest $500B In US Over 4 Years As Tariffs Mount

    Apple said Monday that it would invest $500 billion in the U.S. over the next four years, weeks after President Donald Trump placed a 10% tariff on goods from China, where the company sources components for its products, and threatened tariffs on semiconductors.

  • February 24, 2025

    Aussie Tax Office Agrees To Step Up Safeguards For AI

    The Australian Taxation Office said Monday that it will implement seven recommendations made by a national auditing body regarding the agency's adoption of artificial intelligence tools, including looking closer at potential data ethics risks and the overall development of the programs.

  • February 24, 2025

    High Court Won't Hear Tax Tipster's $690M Award Claim

    The U.S. Supreme Court declined on Monday to review a man's claim for a $690 million whistleblower award for undercover recordings and tips he gave the IRS that he said led to the arrests of Swiss bankers and the success of an offshore tax disclosure program.

  • February 24, 2025

    OECD Issues Consolidated Guidance On Amount B

    The OECD issued consolidated guidance Monday that it put out throughout last year for an internationally agreed-upon method to apply the arm's-length principle to pricing baseline marketing and distribution activities by multinational corporations, known as Amount B of Pillar One.

  • February 21, 2025

    Trump Says Tariffs Coming For Countries With DSTs

    President Donald Trump's administration will impose tariffs on countries with taxes that disproportionately affect American companies, such as digital services taxes, which mainly apply to tech giants, according to a memorandum released late Friday.

  • February 21, 2025

    The Tax Angle: ABA Midyear Tax Meeting

    With a lack of government officials attending the American Bar Association's midyear tax meeting, here's a peek into a reporter's notebook on a few of the week's developing tax stories.

  • February 21, 2025

    China Says Tax Deferral Boosted Foreign Reinvestment

    A tax regime exempting foreign investors from withholding taxes on certain profits generated by their China-based businesses as long as those profits are directly reinvested in projects in China led to a 15% year-over-year increase in foreign reinvestment, the country's tax administration said Friday.

  • February 21, 2025

    French 2% Minimum Wealth Tax Advances In Parliament

    French households with assets worth more than €100 million ($104.6 million) would be subject to a 2% minimum tax on their net worth annually under a top-up wealth tax proposal approved by the lower house of France's Parliament.

  • February 21, 2025

    IRS, Engineer Resolve Fight Over $5.5M In FBAR Penalties

    The U.S. government and an engineer have resolved a dispute over $5.5 million in penalties and interest regarding the nondisclosure of assets in her foreign accounts from 2009 to 2012, according to a judgment entered by a California federal court.

  • February 21, 2025

    Australia Lays Out Eligibility For Hydrogen, Mineral Credits

    The Australian Taxation Office released guidance for companies hoping to claim either of a pair of new tax incentives aimed at hydrogen and critical mineral production, including eligibility requirements and how to claim the credits.

  • February 21, 2025

    DLA Piper Tax Attorney Jumps To Vedder Price In Chicago

    Vedder Price PC has expanded its Chicago office with the addition of a skilled tax attorney who brings nearly 30 years of experience, most recently with DLA Piper.

  • February 21, 2025

    Taxation With Representation: Kirkland, V&E, Cravath, Dechert

    In this week's Taxation With Representation, Diamondback Energy buys Midland Basin assets from another oil and natural gas company, GTCR closes its second strategic growth fund, Light & Wonder Inc. buys Grover Gaming's assets, and Barings acquires Artemis Real Estate Partners.

  • February 21, 2025

    EU Tax Blacklist Needs New Criteria, Tax Pros Say

    The European Union's list of uncooperative tax jurisdictions needs new criteria to tackle the problem of corporate tax avoidance and harmful tax practices, tax campaigners claimed Friday.

  • February 21, 2025

    UK, Andorra Agree To Double-Tax Treaty

    The U.K. and Andorra have reached an agreement on a treaty to prevent double taxation that will go into effect once it is approved by both countries' legislatures, HM Revenue & Customs said Friday.

  • February 21, 2025

    UK Sticks With Inheritance Tax Changes Amid Higher Revenue

    A U.K. budget surplus, reported Friday, indicates that the Labour government shows no sign of compromising with its inheritance tax changes as tax receipts rise despite the implications for middle-class families and farmers.

  • February 20, 2025

    Biz Groups Pan Worldwide Reporting In Md. Tax Package

    Worldwide combined reporting for corporations in Maryland, along with other provisions in a legislative tax proposal, would discourage business investment in the state, business groups told a state House panel Thursday.

  • February 20, 2025

    Bradley Arant Adds Securities, Tax Expert As Partner

    Bradley Arant Boult Cummings LLP added a former Burr & Forman LLP partner to the firm's tax group and corporate and securities group in its Birmingham, Alabama, office.

  • February 20, 2025

    IRS Worker Layoff Could Hamper Enforcement, Groups Warn

    Congressional Democrats, tax and economic policy groups and an IRS workers union warned Thursday that the termination of thousands of Internal Revenue Service employees that began the same day could threaten the agency's ability to enforce tax laws and hamper taxpayer services amid tax-filing season.

  • February 20, 2025

    Guinea Fends Off Push To Enforce $22M Telecom Award

    A D.C. federal court said it lacked jurisdiction to enforce a $22 million arbitration award against the Republic of Guinea stemming from a system enabling the country to tax international telecommunications traffic, saying the nation wasn't a party to the underlying arbitration agreement.

Expert Analysis

  • Firms Still Have The Edge In Lateral Hiring, But Buyer Beware

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    Partner mobility data suggests that the third quarter of this year continued to be a buyer’s market, with the average candidate demanding less compensation for a larger book of business — but moving into the fourth quarter, firms should slow down their hiring process to minimize risks, say officers at Decipher Investigative Intelligence.

  • Think Like A Lawyer: 1 Type Of Case Complexity Stands Out

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    In contrast to some cases that appear complex due to voluminous evidence or esoteric subject matter, a different kind of complexity involves tangled legal and factual questions, each with a range of possible outcomes, which require a “sliding scale” approach instead of syllogistic reasoning, says Luke Andrews at Poole Huffman.

  • Think Like A Lawyer: Note 3 Simple Types Of Legal Complexity

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    Cases can appear complex for several reasons — due to the number of issues, the volume of factual and evidentiary sources, and the sophistication of those sources — but the same basic technique can help lawyers tame their arguments into a simple and persuasive message, says Luke Andrews at Poole Huffman.

  • Litigation Inspiration: Reframing Document Review

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    For attorneys — new ones especially — there is much fulfillment to find in document review by reflecting on how important, interesting and pleasant it can be, says Bennett Rawicki at Hilgers Graben.

  • 3 Ways To Train Junior Lawyers In 30 Minutes Or Less

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    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.

  • The Bar Needs More Clarity On The Discovery Objection Rule

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    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.

  • So You Want To Move Your Law Practice To Canada, Eh?

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    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.

  • Promoting Diversity In The Selection Of ADR Neutrals

    Excerpt from Practical Guidance
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    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.

  • 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.

  • How Judiciary Can Minimize AI Risks In Secondary Sources

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    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.

  • 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.

  • Lawyers With Disabilities Are Seeking Equity, Not Pity

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    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.

  • 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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