International

  • September 03, 2024

    Non-EU Cos. Need Clarity On Public Tax Reporting, Firms Say

    The European Union should clarify how multinational corporations headquartered outside the bloc need to format tax data they report under new public disclosure rules, global accounting firms said.

  • September 03, 2024

    Higher UK Windfall Tax Will Cut Revenue, Says Industry Group

    The U.K. government's plan to raise the energy windfall tax in November may cost HM Treasury around £12 billion ($15.7 billion) in tax revenue, according to an industry group.

  • September 03, 2024

    Norway Seeks Input On Beneficial Ownership Register Access

    Norway's Ministry of Finance is seeking comments on a proposal laying out rules regarding access to the country's beneficial ownership register, the ministry said Tuesday.

  • September 03, 2024

    IRS Issues More Edits For Foreign Currency Accounting Regs

    The Internal Revenue Service issued further corrections Tuesday to proposed rules that would adjust the timing for when companies can use certain accounting methods for gains or losses that arise from foreign currency transactions.

  • August 30, 2024

    Alvarez & Marsal Appoints Tax Experts As Managing Directors

    Alvarez & Marsal Tax LLC appointed tax experts from Anderson and Deloitte as its new managing directors, the firm announced.

  • August 30, 2024

    Danish Gov't Pledges No Ponzi Analogies At $2.1B Tax Trial

    The Danish tax authority won't compare pension funds, investors and attorneys it has accused of defrauding Denmark in a $2.1 billion tax refund scheme to a Ponzi scheme or infamous perpetrator Bernie Madoff, it said Friday in New York federal court.

  • August 30, 2024

    US Seeks Trade Talks In Dispute Over Canada's Digital Tax

    The Office of the U.S. Trade Representative announced Friday that it has requested dispute settlement discussions with Canada regarding the country's recently enacted digital services tax, which the USTR claims discriminates against U.S. companies.

  • August 30, 2024

    Whistleblower Seeks 2nd Bid At $690M Claim In DC Circ.

    A whistleblower denied up to $690 million, or 30%, of the $2.3 billion collected in an Internal Revenue Service offshore voluntary disclosure program asked for a D.C. Circuit panel to rehear his case Friday, saying its original opinion included numerous mistakes and misunderstandings.

  • August 30, 2024

    UK's Labour Gov't Urged To Raise Capital Gains Tax

    The Labour government is facing calls to raise the capital gains tax despite financial firms advising investors to sell off their assets or even leave the United Kingdom over the possible tax hike.

  • August 30, 2024

    IRS Corrects Proposed Rules To Address Pillar 2 Losses

    The Internal Revenue Service issued corrections Friday to proposed rules that outline when foreign taxes under the Pillar Two international minimum tax agreement could trigger long-standing U.S. rules that aim to prevent companies from what is known as double-dipping the same economic loss.

  • August 30, 2024

    Taxation With Representation: Kirkland, Paul Weiss, Squire

    In this week's Taxation With Representation, Oneok reaches two agreements with energy infrastructure companies worth a total $5.9 billion, McKesson inks a $2.49 billion deal for a cancer center, and First Busey and CrossFirst Bankshares agree to a $917 million merger.

  • August 30, 2024

    Neb. Justices Affirm Nix Of Berkshire Unit's Tax Deduction Bid

    A Nebraska tax deduction for certain dividends doesn't apply to income repatriated under the 2017 federal tax overhaul, the state Supreme Court affirmed Friday in rejecting arguments from a Berkshire Hathaway entity that the state's tax system excluded the foreign earnings from tax.

  • August 29, 2024

    Tax Court Rejects Bid To Change Ruling Post-Chevron

    The U.S. Supreme Court's recent overturning of the Chevron standard of judicial deference to agencies when interpreting statutes does not justify reconsidering a Cayman Islands partnership's tax liability, the U.S. Tax Court ruled.

  • August 29, 2024

    4th Circ. Won't Revive Whistleblower's Credit Suisse Tax Suit

    The Fourth Circuit upheld the dismissal of a former Credit Suisse employee's whistleblower case that alleged the Swiss bank continued to help clients evade taxes after it made a related plea deal with the U.S., saying a 2023 U.S. Supreme Court decision on the False Claims Act could not save the case.

  • August 29, 2024

    Tax Admins Advised To Tailor Structures To Needs Over Time

    Tax administrations must tailor their organization structures to their specific challenges and environments to adapt to modern problems, not just reshuffle organization charts, several international tax groups said Thursday.

  • August 29, 2024

    Day Pitney Lands Former Reuters Tax Counsel In Conn.

    Day Pitney LLP continued its recent growth in its tax practice in Connecticut with the addition of an experienced tax attorney from Thomson Reuters.

  • August 29, 2024

    EU Should Ensure Public Understands Tax Data, Execs Say

    The European Union should specify that its disclosure requirements for corporate tax information don't reflect multinational companies' overall operations, a group representing in-house tax practitioners said in comments published Thursday, saying the public could otherwise misunderstand the data.

  • August 29, 2024

    Brazil Seeks Comments On Transfer Pricing Guidelines

    Brazil is seeking public comments on proposed regulations related to its 2023 adoption of new transfer pricing rules, including the application of the international arm's-length standard, the country's revenue agency said Thursday.

  • August 29, 2024

    UK Reports £300M Rise In Tax Relief To Creative Industries

    Creative industries received £2.2 billion ($2.9 billion) in tax relief from the U.K. in the 2022-23 tax year, an increase of £300 million over the prior year largely driven by more claims from high-end TV and theater productions, HM Revenue & Customs said Thursday.

  • August 29, 2024

    Sky Sports Rugby Pundit Loses Bid To Duck £700K Tax Bill

    Rugby commentator Stuart Barnes has lost his attempt to escape a tax bill of almost £700,000 ($921,000) as a tribunal ruled that he owed the money because a contract between his company and Sky was equivalent to an employer-employee relationship.

  • August 28, 2024

    IRS Declines Watchdog's Ask For Attys In Talks With Big Cos.

    The IRS declined a recommendation by its internal watchdog to require the agency's counsel to attend talks held with large multinational corporations by its appellate division, which agents say thwarts their ability to correctly enforce the economic substance doctrine, according to a report.

  • August 28, 2024

    Feds Looks To Toss Ex-Citizens' Renunciation Fee Challenge

    The federal government asked a D.C. federal judge to throw out a lawsuit brought by former U.S. citizens who want their $2,350 citizenship renunciation fee refunded, arguing during a Wednesday hearing that the United States is immune from the litigation and the plaintiffs can't relitigate claims that they already lost.

  • August 28, 2024

    IRS Corrects Proposed Foreign Currency Accounting Regs

    The Internal Revenue Service issued corrections Wednesday to proposed rules that would adjust the timing for when companies could opt to use what is known as the mark-to-market accounting method for gains or losses that arise from foreign currency transactions.

  • August 28, 2024

    Jury Justified In Dismissing $2.2M FBAR Case, Court Rules

    A financial adviser will not face a new trial after an Arizona federal court ruled there was sufficient evidence for a jury to clear him in January of failing to report foreign bank accounts, sparing him at least $2.2 million in penalties.

  • August 28, 2024

    Sysco, IRS Asked To Address Varian's Foreign Dividend Win

    The U.S. Tax Court asked food services giant Sysco and the IRS to address how a tax dispute between them is affected by a recent ruling in a similar case that found medical device company Varian can claim a deduction for foreign dividends.

Expert Analysis

  • A Post-Mortem Analysis Of Stroock's Demise

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    After the dissolution of 147-year-old firm Stroock late last year shook up the legal world, a post-mortem analysis of the data reveals a long list of warning signs preceding the firm’s collapse — and provides some insight into how other firms might avoid the same disastrous fate, says Craig Savitzky at Leopard Solutions.

  • SG's Office Is Case Study To Help Close Legal Gender Gap

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    As women continue to be underrepresented in the upper echelons of the legal profession, law firms could learn from the example set by the Office of the Solicitor General, where culture and workplace policies have helped foster greater gender equality, say attorneys at Ocean Tomo.

  • Reimagining Law Firm Culture To Break The Cycle Of Burnout

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    While attorney burnout remains a perennial issue in the legal profession, shifting post-pandemic expectations mean that law firms must adapt their office cultures to retain talent, say Kevin Henderson and Eric Pacifici at SMB Law Group.

  • Cayman Islands Off AML Risk Lists, Signaling Robust Controls

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    As a world-leading jurisdiction for securitization special purpose entities, the removal of the Cayman Islands from increased anti-money laundering monitoring lists is a significant milestone that will benefit new and existing financial services customers conducting business in the territory, say lawyers at Walkers Global.

  • The Legal Industry Needs A Cybersecurity Paradigm Shift

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    As law firms face ever-increasing risks of cyberattacks and ransomware incidents, the legal industry must implement robust cybersecurity measures and privacy-centric practices to preserve attorney-client privilege, safeguard client trust and uphold the profession’s integrity, says Ryan Paterson at Unplugged.

  • As Promised, IRS Is Coming For Crypto Tax Evaders

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    The IRS is fulfilling its promise to crack down on those who have neglected to pay taxes on cryptocurrency earnings, as demonstrated by recently imposed prison sentences, enforcement initiatives and meetings with international counterparts — suggesting a few key takeaways for taxpayer compliance, say attorneys at BakerHostetler.

  • 5 Reasons Associates Shouldn't Take A Job Just For Money

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    As a number of BigLaw firms increase salary scales for early-career attorneys, law students and lateral associates considering new job offers should weigh several key factors that may matter more than financial compensation, say Albert Tawil at Lateral Hub and Ruvin Levavi at Power Forward.

  • The Pop Culture Docket: Judge Djerassi On Super Bowl 52

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    Philadelphia Court of Common Pleas Judge Ramy Djerassi discusses how Super Bowl 52, in which the Philadelphia Eagles prevailed over the New England Patriots, provides an apt metaphor for alternative dispute resolution processes in commercial business cases.

  • Employee Experience Strategy Can Boost Law Firm Success

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    Amid continuing business uncertainty, law firms should consider adopting a holistic employee experience strategy — prioritizing consistency, targeting signature moments and leveraging measurement tools — to maximize productivity and profitability, says Haley Revel at Calibrate Consulting.

  • 6 Practice Pointers For Pro Bono Immigration Practice

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    An attorney taking on their first pro bono immigration matter may find the law and procedures beguiling, but understanding key deadlines, the significance of individual immigration judges' rules and specialized aspects of the practice can help avoid common missteps, says Steven Malm at Haynes Boone.

  • Lessons From Country Singer's Personal Service Saga

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    Recent reports that country singer Luke Combs won a judgment against a Florida woman who didn’t receive notice of the counterfeit suit against her should serve as a reminder for attorneys on best practices for effectuating service by electronic means, say attorneys at Jenner & Block.

  • 7 E-Discovery Predictions For 2024 And Beyond

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    The legal and technical issues of e-discovery now affect virtually every lawsuit, and in the year to come, practitioners can expect practices and policies to evolve in a number of ways, from the expanded use of relevancy redactions to mandated information security provisions in protective orders, say attorneys at Littler.

  • 5 Litigation Funding Trends To Note In 2024

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    Over the next year and beyond, litigation funding will continue to evolve in ways that affect attorneys and the larger litigation landscape, from the growth of a secondary market for funded claims, to rising interest rates restricting the availability of capital, says Jeffery Lula at GLS Capital.

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