International
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June 26, 2024
Fed. Circ. Denies Contractor's $37M Tax Reimbursement Bid
A U.S. State Department armed security contractor is not entitled to $37 million in reimbursement tied to tax payments to the Afghan government because the contractor's parent company, not the company itself, incurred the costs associated with the payments, the Federal Circuit said Wednesday.
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June 26, 2024
Medical Device Co. To Pay $935K Atty Fees In Tax Fraud Suit
A medical equipment company's leaders will pay $935,000 in attorney fees to investors' counsel after mediating a settlement in a proposed class action alleging the company breached fiduciary duty in failing to disclose its former CEO's involvement in a tax fraud dispute with Denmark.
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June 26, 2024
Kenya President Backs Off Finance Bill After Fatal Protests
Kenyan President William Ruto said Wednesday that he will withdraw a controversial finance bill that included tax hikes that inspired mass protests, including storming the country's Parliament building leaving multiple people dead, according to local news reports.
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June 26, 2024
EU Justice Head Loses Bid To Lead Human Rights Group
The European Union's justice commissioner failed in his bid to lead a European human rights organization and returned Wednesday from his leave of absence for the remaining four months of his term as commissioner.
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June 26, 2024
EU State Auditors Must Respect Tax Incentives, Lawyer Says
European Union countries need to make sure that their tax authorities are supporting incentive programs, such as those related to research and development, rather than interpreting laws in inconsistent ways, a tax lawyer said Wednesday.
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June 26, 2024
Irish Pick New Finance Minister After Former Heads To EU
Ireland picked a current junior minister as its new finance minister, the ministry confirmed to Law360 on Wednesday, one day after the government nominated the outgoing finance minister to serve on the next European Commission.
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June 25, 2024
US Needs To Broaden Tax Base, Increase Rates, OECD Says
The United States' debt-to-gross-domestic-product ratio is the highest it's been since World War II, necessitating a wide range of tax changes to both expand the tax base and increase rates to alleviate fiscal pressures, the OECD said Tuesday.
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June 25, 2024
Pharma Co. Teva To Pay Israel $750M In Tax Debt Settlement
Israel-based multinational Teva Pharmaceutical Industries Ltd. reached an agreement with the Israel Tax Authority to settle 12 years' worth of pending tax litigation by paying $750 million over the course of five years, the company said Tuesday.
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June 25, 2024
Asia, Pacific Tax-To-GDP Ratio Returns To Pre-COVID Level
Tax revenue in Asia and the Pacific rebounded to pre-pandemic levels in 2022 thanks to boosts in tourism and commodity prices, but the region's average tax-to-gross domestic product ratio is still lagging behind the average OECD ratio, the group said Tuesday.
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June 25, 2024
Pension Plans Can't Escape $2B Danish Tax Fraud Dispute
Two U.S. pension plans made an "extremely strained" contention that Denmark's tax administrator waited too long to accuse them of participating in a $2.1 billion fraud scheme, a New York federal judge said in declining to toss the case.
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June 25, 2024
Hong Kong, Armenia Reach Double-Tax Treaty Deal
Hong Kong signed an agreement with Armenia on a treaty to prevent double taxation as part of a larger goal to establish such treaties with countries participating in China's Belt and Road global infrastructure project, Hong Kong's Inland Revenue Department said.
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June 25, 2024
Ex-DOJ Atty Among New Trio At Chamberlain Hrdlicka
Chamberlain Hrdlicka White Williams & Aughtry has strengthened its tax controversy and litigation practice with the addition of three attorneys in Atlanta, including a former senior trial attorney in the Tax Division of the U.S. Department of Justice for more than three decades.
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June 25, 2024
J&J Counsel Urges OECD To Ease Burdens Of Global Min. Tax
Counsel for Johnson & Johnson on Tuesday urged the OECD and government officials working on the Pillar Two global minimum corporate tax to consider more permanent safe harbor provisions to reduce the compliance burdens associated with the levy.
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June 25, 2024
Global Tax Overhaul Won't Squash Competition, US Rep. Says
The global tax overhaul designed by the Organization for Economic Cooperation and Development won't eliminate countries competing for companies' investments, a U.S. House lawmaker said Tuesday.
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June 25, 2024
EU Leaders To Include Tax Revamp In 5-Year Plan, Draft Says
A targeted makeover of the tax systems in European Union countries will be part of the bloc's top priorities for the next five years as it aims to improve business financing to sharpen its competitiveness, a draft document suggested.
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June 25, 2024
New EU Chair Hungary Eyes Talks On Corp. Tax, But No Deals
Hungary, the incoming chair of meetings of European Union countries, plans to discuss energy taxation and several proposals on corporate taxation during the next six months but doesn't expect to reach any agreements, according to meeting agendas.
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June 24, 2024
Miner Wins $9.6M In Royalty Fight With Colombia
An international tribunal ordered Colombia to pay $9.56 million to a British mining and metals company following a dispute over royalties collected on a nickel mine, as the tribunal concluded that there had been "irregularities" in the way the country calculated the amount due.
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June 24, 2024
UN Tax Work Threatens OECD's Progress, EU Official Says
The United Nations' efforts to consider international tax issues risk upending the early finished work of countries negotiating a global tax plan at the Organization for Economic Cooperation and Development, a top European Commission tax official said Monday.
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June 24, 2024
Better Digital Tax Ban In Pillar 1 Treaty, Treasury Official Says
The final text of a multilateral convention to implement the OECD-designed taxing rights overhaul will include improved language to eliminate existing digital services tax and prohibit prospective ones, a U.S. Treasury Department official said Monday.
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June 24, 2024
Loss Guidance Will Cover Pillar 2, IRS Official Says
Forthcoming guidance to address U.S. tax issues with dual consolidated losses will also include language advising taxpayers how to account for those losses under the Pillar Two global minimum tax, the IRS' top international tax counsel said Monday.
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June 24, 2024
UN Tax Convention Should Be Crafted Carefully, NFTC Says
The United Nations' work toward a framework convention on international tax cooperation is welcome but should be done carefully and with continued input from stakeholders, the National Foreign Trade Council said, providing specific areas of feedback.
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June 24, 2024
German Banker's Cum-Ex Trial Dropped Due To Health
The former chairman of M.M. Warburg & Co. KGaA will not face trial for alleged dividend-tax evasion linked to cum-ex transactions spanning from 2006 to 2019 after a German court halted the trial due to his health, according to a Monday court statement.
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June 24, 2024
Asia Tax Transparency Generated €1.8B In Revenue In 2023
Tax transparency measures in 13 Asian jurisdictions collected at least €1.8 billion ($1.9 billion) in extra tax revenue in 2023 alone as such mechanisms continue to be adopted in the region, the Organization for Economic Cooperation and Development reported Monday.
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June 24, 2024
EU Dodges Hungary To Send Ukraine €1.4B In Russian Profits
European Union foreign ministers agreed Monday to send €1.4 billion ($1.5 billion) of windfall profits from frozen and immobilized Russian state assets in military support to Ukraine next month, finding a legal loophole to bypass a potential veto from Hungary.
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June 24, 2024
OECD Tax Plan Issues Still Being Hashed Out, US Official Says
Both the global minimum corporate tax and taxing rights overhaul plans designed by the Organization for Economic Cooperation and Development have outstanding issues that stakeholders are attempting to resolve, a U.S. Treasury Department official said at a conference Monday.
Expert Analysis
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Unpacking The Bill To Extend TCJA's Biz-Friendly Tax Breaks
Attorneys at Skadden examine how a bipartisan bill currently being considered by the U.S. Senate to save the Tax Cuts and Jobs Act's tax breaks for research and development costs, and other expiring business-friendly provisions, would affect taxpayers.
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Deciding What Comes At The End Of WTO's Digital Tariff Ban
Companies that feel empowered by the World Trade Organization’s recent two-year extension of the ban on e-commerce tariffs should pay attention to current negotiations over what comes after the moratorium expires, as these agreements will define standards in international e-commerce for years to come, say Jan Walter, Hannes Sigurgeirsson and Kulsum Gulamhusein at Akin Gump.
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4 Ways To Refresh Your Law Firm's Marketing Strategy
With many BigLaw firms relying on an increasingly obsolete marketing approach that prioritizes stiff professionalism over authentic connection, adopting a few key communications strategies to better connect with today's clients and prospects can make all the difference, say Eric Pacifici and Kevin Henderson at SMB Law.
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This Earth Day, Consider How Your Firm Can Go Greener
As Earth Day approaches, law firms and attorneys should consider adopting more sustainable practices to reduce their carbon footprint — from minimizing single-use plastics to purchasing carbon offsets for air travel — which ultimately can also reduce costs for clients, say M’Lynn Phillips and Lisa Walters at IMS Legal Strategies.
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Cum-Ex Prosecutions Storm Shows No Sign Of Abating
The ongoing trial of Sanjay Shah in Denmark is a clear indicator that efforts remain focused on holding to account the alleged architects and beneficiaries of cum-ex trading, and with these prosecutions making their way across Europe, it is a more turbulent time now than ever, says Niall Hearty at Rahman Ravelli.
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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.