International
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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.
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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.
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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.
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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.
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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.
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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.
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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.
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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.
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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.
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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.
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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.
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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.
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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.
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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.
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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.
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February 20, 2025
Europol Says Money-Laundering Gang Members Arrested
European Union law enforcement officials arrested 14 individuals, primarily Russian citizens, whom they accused of laundering money for drug traffickers and other criminal groups, during raids last month in Spain and Portugal, according to a news release.
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February 20, 2025
Bilzin Sumberg Adds Ex-KPMG Tax Pro In Miami
Miami-based Bilzin Sumberg Baena Price & Axelrod LLP announced Thursday that it has hired an experienced tax attorney who previously worked as a managing director with Big 4 accounting firm KPMG as a partner.
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February 20, 2025
Swiss Gov't Looks To Extend Tax Data Sharing To Crypto
The Swiss government is looking to extend the automatic information exchange of tax data to include crypto-asset holdings, treating cryptocurrencies like traditional assets, according to a statement.
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February 20, 2025
Third Of Pension Professionals Uncertain About Gov't Policy
Approximately one in three pension professionals is unclear about the government's priorities for the sector, research by a specialist law firm has suggested, with particular uncertainty over proposals to apply tax to wealth passed on through retirement savings plans.
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February 19, 2025
Miller & Chevalier Adds Former IRS Chief Counsel
Miller & Chevalier Chtd. has found a new co-leader for its tax controversy and litigation practice as it brings aboard the former chief counsel of the Internal Revenue Service during President Donald Trump's first term.
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February 19, 2025
FinCEN Sets March Deadline For Corporate Transparency Act
The U.S. Treasury Department's Financial Crimes Enforcement Network set a new deadline of March 21 for an estimated 32 million small entities to file beneficial ownership reports relating to the Corporate Transparency Act after a Texas federal judge lifted a block on the law's enforcement.
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February 19, 2025
McCarter & English Adds Shutts & Bowen Latin America Head
The former chair of the Shutts & Bowen LLP's Latin America practice group and co-chair of its tax and international law practice group jumped to McCarter & English LLP in Miami, the firm announced Wednesday.
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February 19, 2025
Minn. House Bill Seeks Corporate Tax Break On GILTI
Minnesota would eliminate state corporate taxation of global intangible low-taxed income and boost corporate tax deductions under legislation introduced in the state House.
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February 18, 2025
Dems Push Corporate Transparency Act Legitimacy To Courts
Congress has the authority to establish a nationwide registry of the beneficial owners of legal entities by passing the Corporate Transparency Act, a group of Democratic legislators said in similar amicus briefs filed in appellate courts.
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February 18, 2025
DC Court Asked To Block DOGE's Access To Taxpayer Data
A federal judge should block the U.S. Treasury Department's reported provision of taxpayer data to the Department of Government Efficiency, halt DOGE's access and order its software uninstalled from Treasury systems, unions and advocacy organizations said in a complaint.
Expert Analysis
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Mental Health First Aid: A Brief Primer For Attorneys
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.
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The Trade And Tax Issues Behind US-Canada Digital Tax Clash
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.
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Litigation Inspiration: Honoring Your Learned Profession
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.
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AI May Limit Key Learning Opportunities For Young Attorneys
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.
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Ruling On Foreign Dividend Break Offers 2 Tax Court Insights
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.
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Why Now Is The Time For Law Firms To Hire Lateral Partners
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.
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Considering Possible PR Risks Of Certain Legal Tactics
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.
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It's No Longer Enough For Firms To Be Trusted Advisers
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.
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Navigating A Potpourri Of Possible Transparency Act Pitfalls
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.
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How Methods Are Evolving In Textualist Interpretations
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.
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Why Attorneys Should Consider Community Leadership Roles
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.
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Firms Must Offer A Trifecta Of Services In Post-Chevron World
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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5 Tips To Succeed In A Master Of Laws Program And Beyond
As lawyers and recent law school graduates begin their Master of Laws coursework across the country, they should keep a few pointers in mind to get the most out of their programs and kick-start successful careers in their practice areas, says Kelley Miller at Reed Smith.