International

  • October 23, 2024

    ABA Tax Section Pushes IRS To Narrow Pillar 2 Regulations

    Proposed regulations outlining when foreign taxes under the Pillar Two international minimum tax agreement trigger U.S. rules against benefiting twice from the same economic loss should be narrowed to limit their applicability, the American Bar Association Tax Section told the IRS.

  • October 23, 2024

    IRS Grants Tax-Exempt Entities Relief From Corp. AMT Filing

    Tax-exempt entities are not obligated to file the corporate alternative minimum tax form for the 2023 tax year with the Internal Revenue Service, but they should still maintain the document for recordkeeping purposes, the agency announced Wednesday. 

  • October 23, 2024

    EU OKs Swedish Biogas Tax Breaks After Review

    Two Swedish tax exemptions — one for nonfood-based biogas, the other for biopropane used for heating — are in line with European Union state aid rules, the European Commission said Wednesday following a probe into the measures.

  • October 23, 2024

    Judge Threatens To Toss Gov't's $4.9M Son-Of-Boss Claim

    A federal judge warned government attorneys Wednesday that she would dismiss their case against an estate for $4.9 million in taxes if they didn't explain why they weren't actively pursuing their accusations that a Michigan couple schemed to artificially cancel out capital gains

  • October 23, 2024

    Jersey Adopts Global Minimum Tax

    Jersey has adopted the Organization for Economic Cooperation and Development's 15% minimum tax on multinational entities making over €750 million ($808 million) annually, which will take effect in the jurisdiction in 2025.

  • October 23, 2024

    MVP: Sullivan & Cromwell's Eric Wang

    Sullivan & Cromwell's S. Eric Wang advised clients on the tax law implications of major deals over the past year, including a transaction that created the largest gas utility company in North America, earning him a spot as one of the 2024 Law360 2024 Tax MVPs.

  • October 22, 2024

    8th Circ. Judge Presses IRS On 3M Transfer Pricing Tax Ruling

    An Eighth Circuit judge cast doubt during oral arguments Tuesday on the government's interpretation of regulations the IRS relied on to reallocate almost $24 million of income to 3M from its Brazilian affiliate that was subject to legal restrictions on royalty payments.

  • October 22, 2024

    New IRS Unit Starts Work On Pass-Through Compliance

    A new Internal Revenue Service unit focused on the compliance of pass-through entities of all sizes and forms, such as partnerships, S corporations and trusts, has officially started work, the agency said Tuesday.

  • October 22, 2024

    Brazil Eyes Shifting Talks On Wealth Taxation To UN

    Brazil is campaigning for the United Nations to commit to creating a minimum tax on high-net-worth individuals in February during expected talks on the organization's burgeoning global tax convention, a Brazilian finance ministry official said Tuesday at the International Monetary Fund.

  • October 22, 2024

    Argentina President Dissolving, Replacing Tax Agency

    Argentina's tax authority, the Federal Public Revenue Administration, will be dissolved and replaced with a new body, the country's president said, with the change causing a 34% reduction in jobs.

  • October 22, 2024

    Tax Court Says It Can't Rule On FBAR Challenge

    The U.S. Tax Court said Tuesday that it lacks the authority to rule on a couple's claim that the Internal Revenue Service wrongly denied them a chance to challenge penalties for failing to report their foreign bank accounts.

  • October 22, 2024

    Wafer Factories Qualify For CHIPS Tax Credit In Final Regs

    Semiconductor wafer production facilities will qualify for the 25% investment tax credit that incentivizes advanced chip manufacturing development projects under final regulations the U.S. Department of the Treasury released Tuesday.

  • October 22, 2024

    IRS Working On Proposed Spinoff Rules, Agency Official Says

    The Internal Revenue Service is planning to propose regulations that may amend positions in an existing revenue procedure that narrowed the range of spinoff transactions the agency will approve as tax-free ahead of time, an IRS official said Tuesday.

  • October 22, 2024

    Winston & Strawn Boosts Transactions Team With NY Tax Atty

    As Winston & Strawn LLP continues to build out its transactions team, the firm has hired a new attorney from Hunton Andrews Kurth LLP with a focus on the tax aspects of real estate financing.

  • October 22, 2024

    Ireland Deposits €4B In Fund Set Up For Tax Surplus

    Ireland transferred €4.05 billion ($4.4 billion) from its Exchequer to one of the sovereign wealth funds it created to invest surplus revenue generated by what the country's Department of Finance has characterized as volatile corporate tax receipts, the department said Tuesday.

  • October 22, 2024

    Portuguese Parliament Passes Min. Tax After EU Pressure

    Portugal would implement the global corporate minimum tax spearheaded by the Organization for Economic Cooperation and Development under legislation sent to the country's president for approval Tuesday after the European Union put the country on notice for not adopting the tax.

  • October 22, 2024

    The 2024 Prestige Leaders

    Check out our Prestige Leaders ranking, analysis and interactive graphics to see which firms stand out for their financial performance, attractiveness to attorneys and law students, ability to secure accolades and positive legal news media representation.

  • October 22, 2024

    How Law Firms Get And Keep Elite Status

    For decades, a handful of New York-based law firms thoroughly dominated the national consciousness when it came to power, profitability and prestige. But in today's legal market, increased movement of partners and clients from one firm to the next has begun to shake things up and create opportunities for go-getters to ascend the ranks.

  • October 22, 2024

    Director Imprisoned For Concealing £220K Tax Debt

    The former director of a wholesale company has been jailed for 10 months after failing to deliver accounting records when his business went into liquidation owing more than £220,000 ($290,000), the Insolvency Service announced Tuesday.

  • October 22, 2024

    Germany's Sept. Tax Revenue Rises 6.9% Year-On-Year

    Germany's total tax revenue for the month of September reached €86.2 billion ($93.2 billion) after a rise in tax receipts over the summer, an increase of 6.9% year-on-year, the German Ministry of Finance said Tuesday.

  • October 22, 2024

    MVP: Jones Day's Charles 'Chuck' Hodges

    Chuck Hodges, a tax partner with Jones Day, led a gravel company to victory in May at the U.S. Tax Court in a case regarding an $11.1 million sale of a freeway pit, helping him earn a spot as one of the 2024 Law360 Tax MVPs.

  • October 22, 2024

    Budget Fears Spark Surge Of Savers Raiding Pensions

    A third of financial advisers have seen an uptick in customers tapping into their pensions, an investment platform company said, amid speculation the government could reduce the amount that Britons can withdraw without being taxed.

  • October 21, 2024

    BDO Appoints Former HMRC Official, 3 Others To UK Offices

    An HM Revenue & Customs official is among four tax professionals BDO LLP has appointed to its offices in the U.K., the firm announced.

  • October 21, 2024

    Foreign Currency Regs Need Flexibility, Biz Group Says

    The U.S. Treasury Department should allow taxpayers with foreign personal holding companies to get automatic consent to revoke elections on the treatment of foreign currency gains or losses under proposed regulations to align such elections with rules on so-called mark-to-market accounting, the National Foreign Trade Council said.

  • October 21, 2024

    UK Director's Use Of Tax Planning Data Subject For Retrial

    Whether a director of a U.K. company is liable for a breach of confidence over the misuse of information in marketing a complex tax structure is an issue to be retried, a London court ruled.

Expert Analysis

  • Unpacking FinCEN's Proposed Real Estate Transaction Rule

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    Phil Jelsma and Ulrick Matsunaga at Crosbie Gliner take a close look at the Financial Crimes Enforcement Network's recently proposed rulemaking — which mandates new disclosures for professionals involved in all-cash real estate deals — and discuss best next steps for the broad range of businesses that could be affected.

  • Think Like A Lawyer: Forget Everything You Know About IRAC

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    The mode of legal reasoning most students learn in law school, often called “Issue, Rule, Application, Conclusion,” or IRAC, erroneously frames analysis as a separate, discrete step, resulting in disorganized briefs and untold obfuscation — but the fix is pretty simple, says Luke Andrews at Poole Huffman.

  • How New EU Tax And Transfer Pricing Rules May Affect M&A

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    Companies involved in mergers and acquisitions may need to adjust fiscal due diligence procedures to ensure they consider potential far-reaching effects of newly implemented transfer pricing measures, such as newly implemented global minimum tax and European Union anti-tax avoidance directives and proposals, says Patrick Tijhuis at BDO.

  • How Firms Can Ensure Associate Gender Parity Lasts

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    Among associates, women now outnumber men for the first time, but progress toward gender equality at the top of the legal profession remains glacially slow, and firms must implement time-tested solutions to ensure associates’ gender parity lasts throughout their careers, say Kelly Culhane and Nicole Joseph at Culhane Meadows.

  • 7 Common Myths About Lateral Partner Moves

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    As lateral recruiting remains a key factor for law firm growth, partners considering a lateral move should be aware of a few commonly held myths — some of which contain a kernel of truth, and some of which are flat out wrong, says Dave Maurer at Major Lindsey.

  • 6 Pointers For Attys To Build Trust, Credibility On Social Media

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    In an era of information overload, attorneys can use social media strategically — from making infographics to leveraging targeted advertising — to cut through the noise and establish a reputation among current and potential clients, says Marly Broudie at SocialEyes Communications.

  • US-Chile Tax Treaty May Encourage Cross-Border Investment

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    Provisions in the recently effective U.S.-Chile bilateral income tax treaty should encourage business between the two countries, as they reduce U.S. withholding tax on investment income for Chilean taxpayers, exempt certain U.S. taxpayers from Chilean capital gains tax, and clarify U.S. foreign tax credit rules, say attorneys at Kramer Levin.

  • 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.

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