International

  • January 07, 2025

    Baker McKenzie Adds Tax Partners In California And New York

    Baker McKenzie is fortifying its tax practice by hiring a partner in San Francisco with experience in planning tax positions and handling controversies for technology-driven companies and rehiring another in New York who is skilled at state taxes and journalism.

  • January 07, 2025

    Oman Implements Global Minimum Tax

    Large multinational entities making over €750 million ($777 million) annually are now subject to the Organization for Economic Cooperation and Development's 15% corporate global minimum income tax in Oman after the country implemented two portions of the group's standards.

  • January 06, 2025

    Apple Tax Ruling Fuels Most Of Ireland's €12.8B Surplus

    Ireland recorded a €12.8 billion ($13.3 billion) budget surplus in 2024, though all but €1.8 billion of that revenue was the result of the European Union's highest court ordering Apple to repay billions in back taxes and interest, the country's Department of Finance said Monday.

  • January 06, 2025

    Tax Whistleblower Urges High Court To Review $690M Claim

    A whistleblower is asking the U.S. Supreme Court to review his claim for up to $690 million as his share of the $2.3 billion recovered through Internal Revenue Service investigations that he said resulted from his cooperation.

  • January 06, 2025

    Proskauer Adds New Funds Partners In NY, DC

    Proskauer Rose LLP announced Monday it has rung in the new year by adding two new partners to its private funds group, with the addition of a tax expert from Schulte Roth & Zabel LLP in New York and a regulatory specialist from the SEC in Washington, D.C.

  • January 06, 2025

    Indian Accountants Push For Simplified Tax Code

    India should simplify its process for determining the resident status of individuals for tax purposes, a group representing Indian accountants said, offering suggestions in response to the government's call for feedback on how to improve its income tax code.

  • January 06, 2025

    US Wants More Time To Counter Altria's $106M Tax Refund Bid

    Tobacco giant Altria's complaint seeking a $106 million tax refund related to its interests in beverage company Anheuser-Busch requires more research to counter in the event a Virginia federal court decides it can move forward, the U.S. government said in requesting time for potential discovery.

  • January 06, 2025

    France's New Finance Minister Hints At Capital Gains Hike

    The newly formed French government is open to raising the capital gains tax as part of concessions in talks to settle the country's budget for 2025, the finance minister said Monday.

  • January 06, 2025

    UK, Ecuador Double-Tax Treaty Comes Into Force

    Portions of a treaty to prevent double taxation between the U.K. and Ecuador came into force at the start of the year, with two other U.K.-focused portions set to begin in April, HM Revenue & Customs said Monday.

  • January 06, 2025

    Trudeau Steps Down As US-Canada Trade Tensions Simmer

    Canadian Prime Minister Justin Trudeau announced Monday that he will resign as the leader of the country's Liberal Party, setting off a process to replace him in the coming months.

  • January 06, 2025

    Ex-Entain CEO Sues Gambling Watchdog Over Bribery Reveal

    Two former top executives at the predecessor of betting giant Entain have sued the Gambling Commission over claims that the regulator misused their private information by disclosing an investigation into potential bribery.

  • January 06, 2025

    HMRC Faces £20M Libel Case Over Asahi Cargo Fraud Report

    A British logistics company has sued HM Revenue and Customs for as much as £20 million ($25 million), alleging that the tax authority damaged its business by falsely accusing it of dodging tax on shipments of Asahi beer.

  • January 03, 2025

    Potomac Law Group Adds Longtime Tax Leader From Day Pitney

    After an end-of-the-year hiring spree in which Potomac Law Group added four former Rimon PC attorneys, PLG has started 2025 by adding the former leader of Day Pitney's multistate tax practice to its ranks.

  • January 03, 2025

    Trump Taps Former Hill Staffer For Assistant Tax Policy Role

    President-elect Donald Trump has tapped a longtime tax policy lobbyist to serve as the assistant secretary for tax policy at the U.S. Department of the Treasury during his coming second term.

  • January 03, 2025

    Kuwait Implements Global Minimum Tax Starting This Year

    Large multinational entities in Kuwait making over €750 million ($773 million) annually are now subject to the OECD's 15% corporate global minimum income tax, the country's Ministry of Finance said.

  • January 03, 2025

    Investment Firm Calls On UK To Rule Out Pension Tax Hikes

    The U.K. should pledge no changes to pension tax benefits for the next four years to assuage consumer fears of the government following up on hikes to other taxes with more increases, according to a survey by an investment firm.

  • January 03, 2025

    Germany Suspends Tax Treaty With Belarus

    The German government suspended its treaty to avoid double taxation with Belarus as of the new year following Belarus' move to suspend portions of the agreement in June, the German Federal Ministry of Finance said.

  • January 03, 2025

    UK Levy Hike Drives Labor Costs Up In 2025, Think Tank Says

    U.K. businesses are facing a spike in labor costs, thanks to the government's decision to raise employers' National Insurance contributions, a payroll levy used to fund social programs, a think tank said Friday.

  • January 02, 2025

    Japanese Cabinet Approves Backstop To 15% Min. Tax

    Japan's Cabinet approved a backstop to its 15% global minimum tax that would enable authorities to collect on multinational corporations' profits in foreign jurisdictions taxed below the minimum rate, according to the country's Ministry of Finance.

  • January 02, 2025

    Republicans Want Yellen To Answer For Chinese Cyberattack

    Congressional Republicans want U.S. Treasury Secretary Janet Yellen to explain how a Chinese state-sponsored entity hacked into Treasury's computer systems and accessed potentially sensitive information.

  • January 02, 2025

    NJ Residents Freed Of $2.1M Tax Bill On Repatriated Income

    Two New Jersey residents don't owe state tax on income repatriated under the 2017 federal tax overhaul, the state's tax court ruled, saying New Jersey's personal income tax laws don't include deemed dividends as a category of taxable income.

  • January 02, 2025

    Feds Ask High Court To Unpause Corporate Transparency Law

    The federal government is asking the U.S. Supreme Court to lift a Texas judge's injunction against the Corporate Transparency Act, telling the justices in a new application that the 2021 anti-money laundering law's compliance deadlines should take effect while the Fifth Circuit hears the full case.

  • January 02, 2025

    IRS, Treasury Float Regs On Excise Taxes For Drugmakers

    The IRS and Treasury proposed rules for charging excise taxes to drugmakers that refuse to negotiate drug prices with Medicare under requirements of the 2022 tax and climate law, saying the tax only would apply to manufacturers and importers that initially sell the drugs.

  • January 02, 2025

    Consolidated Return Regs Revised With Gender-Neutral Terms

    The IRS and Treasury finalized rules for companies that file consolidated federal income tax returns, saying the new regulations provide needed modernizations to terminology, including removing gender-specific pronouns.

  • January 01, 2025

    US International Tax Issues to Watch In 2025

    As President-elect Donald Trump and Republicans take control of the U.S. government in 2025, policymakers are expected to address changing international provisions in the Internal Revenue Code and reevaluate the country's role in global tax talks. Here, Law360 examines key U.S. international tax policy issues to watch in the new year.

Expert Analysis

  • How Law Firms Can Use Account-Based Marketing Strategies

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    Amid several evolving legal industry trends, account-based marketing can help law firms uncover additional revenue-generating opportunities with existing clients, with key considerations ranging from data analytics to relationship building, say Jennifer Ramsey at stage LLC and consultant Gina Sponzilli.

  • Strategic Succession Planning At Law Firms Is Crucial

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    Senior partners' reluctance to retire, the rise of the nonequity partner tier and generational differences in expectations are all contributing to an increasing number of departures from BigLaw, making it imperative for firms to encourage retirement among senior ranks and provide clearer leadership pathways to junior attorneys, says Laura Leopard at Leopard Solutions.

  • Maximizing Law Firm Profitability In Uncertain Times

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    As threats of an economic downturn loom, firms can boost profits by embracing the power of bottom-line management and creating an ecosystem where strategic financial oversight and robust timekeeping practices meet evolved client relations, says Shireen Hilal at Maior Strategic Consulting.

  • 5th Circ. Ruling Reminds Attys That CBP Can Search Devices

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    The Fifth Circuit’s recent Malik v. Department of Homeland Security decision adds to the chorus of federal courts holding that border agents don’t need a warrant to search travelers’ electronic devices, so attorneys should consider certain special precautions to secure privileged information when reentering the U.S., says Jennifer Freel at Jackson Walker.

  • Enforcement Of International Tax Reporting Is Heating Up

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    Since the U.S. Supreme Court’s February decision in Bittner v. U.S. changed how penalties for failure to report offshore accounts are calculated, recent developments suggest the government is preparing to step up enforcement and vigorously pursue the collection of resulting penalties, say Daniel Silva and Agustin Ceballos at Buchalter.

  • IRS Notice Clarifies R&E Amortization, But Questions Remain

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    The IRS and Treasury Department’s recent notice clarifying the treatment of specified research and experimental expenditures under Section 174 provides taxpayers and practitioners with substantive guidance, but it misses the mark in delineating which expenditures are amortizable, say attorneys at Eversheds Sutherland.

  • Preparing Your Legal Department For Pillar 2 Compliance

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    Multinational entities should familiarize themselves with Pillar Two of the Organization for Economic Cooperation and Development’s BEPs 2.0 project and prepare their internal legal tracking systems for related reporting requirements that may go into effect as early as January, says Daniel Robyn at Ernst & Young.

  • What Large Language Models Mean For Document Review

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    Courts often subject parties using technology assisted review to greater scrutiny than parties conducting linear, manual document review, so parties using large language models for document review should expect even more attention, along with a corresponding need for quality control and validation, say attorneys at Sidley.

  • Participating In Living History Makes Me A Better Lawyer

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    My role as a baron in a living history group, and my work as volunteer corporate counsel for a book series fan association, has provided me several opportunities to practice in unexpected areas of law — opening doors to experiences that have nurtured invaluable personal and professional skills, says Matthew Parker at the Nebraska Department of Health and Human Services.

  • Private Equity Owners Can Remedy Law Firms' Agency Issues

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    Nonlawyer, private-equity ownership of law firms can benefit shareholders and others vulnerable to governance issues such as disparate interests, and can in turn help resolve agency problems, says Michael Di Gennaro at The Law Practice Exchange.

  • How Taxpayers Can Prep As Justices Weigh Repatriation Tax

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    The U.S. Supreme Court might strike down the 2017 federal tax overhaul's corporate repatriation tax in Moore v. U.S., so taxpayers should file protective tax refund claims before the case is decided and repatriate previously taxed earnings that could become entangled in dubious potential Section 965 refunds, say Jenny Austin and Gary Wilcox at Mayer Brown.

  • OFAC Designation Prosecutions Are Constitutionally Suspect

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    Criminal prosecutions based on the Office of Foreign Assets Control’s sanctions-related listing decisions — made with nearly unfettered discretion through an opaque process — present several constitutional issues, so it is imperative that courts recognize additional rights of review, say Solomon Shinerock and Annika Conrad at Lewis Baach.

  • How The OECD Global Tax Proposal Could Affect M&A

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    Following agreement on the Organization for Economic Cooperation and Development’s Pillar Two proposal to introduce a global minimum tax, domestic implementation is expected to have a significant impact on international M&A transactions, with financial modeling, deal structuring, risk allocation and joint venture arrangements likely to be affected, say lawyers at Freshfields.

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