International

  • July 23, 2024

    Newell Says IRS Misapplied Pricing Law In $124M Dispute

    Newell Brands told the U.S. Tax Court the Internal Revenue Service misapplied transfer pricing law to levy almost $124 million in additional taxes and penalties.

  • July 23, 2024

    IRS Notice Signals Direction On Corp. AMT Regs, Official Says

    An Internal Revenue Service notice regarding the U.S. corporate alternative minimum tax can be read as a signal about how the agency will more broadly address the measure's potential for counting offshore income twice, an IRS official said Tuesday.

  • July 23, 2024

    Winston & Strawn Adds MoFo Tax Pro As Partner In NY

    Winston & Strawn LLP has added a transactional tax specialist from Morrison Foerster LLP as a partner with the firm's transactions department and tax practice in New York.

  • July 23, 2024

    India Eyes End Of Digital Tax For E-Commerce, But Not Ads

    Foreign e-commerce companies would be exempted from India's equalization levy, a 2% digital tax, but online advertisers would continue to pay a 6% rate on gross revenues sourced to Indian customers under a budget bill presented Tuesday by the government.

  • July 23, 2024

    Australia Mulling Higher Foreign Resident Capital Gains Tax

    The Australian Treasury said Tuesday it is seeking feedback on a plan to increase the country's capital gains withholding tax rate for foreign residents, among other plans it said will strengthen the country's foreign resident capital gains tax regime.

  • July 23, 2024

    EU Seeking Comments On Digital VAT Exemption Certificate

    The European Commission is seeking public comments on a proposal to replace the current paper version of certificates for value-added tax exemptions with a digital version, the European Union's executive branch said Tuesday.

  • July 23, 2024

    Former Doctor To Be Released From Jail In FBAR Fight

    A former doctor will be released from U.S. custody after a Michigan federal court lifted Tuesday an order of civil contempt against him for failure to pay about $1 million in foreign account reporting penalties.

  • July 23, 2024

    5-Hour Energy Partner Owes No Tax On Sale, DC Circ. Says

    The D.C. Circuit found Tuesday that a Canadian citizen's $6.5 million in gains from her sale of a U.S. partnership interest in a company that sold 5-hour Energy drinks was not federally taxable as inventory income, reversing a U.S. Tax Court ruling.

  • July 23, 2024

    EU Parliament's New Tax Group Head Has Eye On Evasion

    The newly elected chair of the European Parliament's subcommittee on tax affairs said Tuesday that a major committee goal would be to examine the issue of tax fraud and evasion at a multinational level.

  • July 22, 2024

    3 Policies Tax Pros Want Congress To Pass This Year

    As momentum around the House-passed tax break bill has fizzled and election season ramps up, tax experts hope lawmakers use what little time they have left to extend expired research tax breaks, approve the Taiwanese tax agreement and pass disaster relief before the end of the year. Here are three policy changes tax professionals think Congress should make before the end of the year.

  • July 22, 2024

    HMRC Wins Appeal Over Taxation Of Partnership Rewards

    Financial rewards from a partnership were taxable as income even though they were made at the partnership's total discretion and the partners had no legally enforceable right to receive them, a London court ruled, siding with HM Revenue & Customs.

  • July 22, 2024

    Pension Plans Slam Biz Docs In $2B Danish Tax Fraud Case

    Denmark's tax agency has produced experts who are relying on unauthenticated documents in litigation accusing U.S. pension plans of participating in a $2.1 billion fraud scheme, the pension plans claimed in urging a New York federal court to exclude the testimony.

  • July 22, 2024

    Argentina Broadens Access To Beneficial Ownership Info

    Argentina is opening up access to its collection of beneficial ownership information in what it is calling a "significant advance" in transparency and anti-money laundering and terrorist financing measures in line with international standards.

  • July 22, 2024

    UN Aims Tax Convention At Digital Economy, Rich Individuals

    The United Nations General Assembly should take aim at taxation of the digital economy and wealthy individuals in a framework convention on international tax cooperation, according to a U.N. committee's revised draft term of reference released after a consultation.

  • July 22, 2024

    Spain Busts €100M Hydrocarbon VAT Fraud Scheme

    Spanish authorities said they busted a suspected tax fraud scheme involving the sale of large quantities of hydrocarbons at below-market prices that ultimately defrauded Spain out of more than €100 million ($109 million) in corresponding value-added tax payments.

  • July 22, 2024

    South Korea, Turkey Amended Tax Treaty Takes Effect

    An amended version of the treaty to avoid double taxation between South Korea and Turkey, which features lower maximum tax rates on dividend and interest income earned by those covered by the treaty, has taken effect, South Korea said.

  • July 22, 2024

    Kyocera Failed To Back R&D Credits With Records, US Says

    Multinational electronics maker Kyocera AVX Components Corp. failed to back up its claim to research tax credits with the required paperwork, the U.S. government told a South Carolina federal court in asking it to stop part of the company's nearly $9 million refund suit from going to trial.

  • July 22, 2024

    Challenge To Romanian Trading Tax Referred To ECJ

    Europe's highest court has been handed a challenge to trading tax in Romania, as a national court seeks guidance on whether EU law would prevent a member country from creating an extra tax liability for some participants in the wholesale energy market.

  • July 19, 2024

    Edwin Coe Adds To Team Ahead Of Planned UK Tax Changes

    Edwin Coe LLP is preparing for an expected surge in disputes following the U.K.'s planned tax changes by hiring as a partner a Harbottle & Lewis lawyer with expertise in litigation and tax planning, according to a news release.

  • July 19, 2024

    Luxembourg Floats Corp. Tax Cut To Boost Attractiveness

    Corporations in Luxembourg may see their income tax rate drop by a percentage point in a bid to make the country more attractive to businesses as part of a larger proposed tax package presented by its finance minister.

  • July 19, 2024

    6 Nations Must Improve Transparency Measures, OECD Says

    Six countries were found largely compliant with the Organization for Economic Cooperation and Development's tax transparency and exchange of information measures due to needed improvements to their beneficial ownership information mechanisms, the organization said Friday.

  • July 19, 2024

    Attorney Denied Separate Trial In $2.1B Danish Tax Fraud

    An attorney facing trial alongside his clients for alleged ties to a $2.1 billion Danish tax fraud has been denied a separate hearing by a New York federal court, which remained unconvinced that his co-workers' advice to the clients could rebound on him prejudicially in a joint trial.

  • July 19, 2024

    Taxation With Representation: A&O Shearman, Gibson Dunn

    In this week's Taxation With Representation, Cleveland-Cliffs Inc. buys Stelco Holdings Inc., KBR acquires LinQuest Corp., Blue Owl Capital Inc. purchases Atalaya Capital Management LP, and Amphenol Corp. buys two mobile networks units from CommScope.

  • July 19, 2024

    2 Arrested In €8.8M VAT Fraud Involving Cleaning Products

    Italian financial police arrested two people Friday who are suspected of leading an €8.8 million ($9.6 million) value-added tax fraud scheme involving cleaning products and beverages, the European Public Prosecutor's Office said.

  • July 19, 2024

    Gov't Floats Draft Proposal For OBR 'Fiscal Lock' Powers

    HM Treasury proposals for a new "fiscal lock" in a draft Budget Responsibility Bill will allow the Office for Budget Responsibility to scrutinize any tax-and-spend decisions with a cost factor of 1% of gross domestic product or more.

Featured Stories

  • Hungary's EU Leadership Could Slow Tax Progress

    Todd Buell

    Hungary's six-month term leading meetings of European Union ministers could hinder progress toward agreement on tax legislation, as the country's position on the war in Ukraine alienates other bloc members.

  • 3 Policies Tax Pros Want Congress To Pass This Year

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    As momentum around the House-passed tax break bill has fizzled and election season ramps up, tax experts hope lawmakers use what little time they have left to extend expired research tax breaks, approve the Taiwanese tax agreement and pass disaster relief before the end of the year. Here are three policy changes tax professionals think Congress should make before the end of the year.

  • International Tax Policy To Watch In The 2nd Half Of 2024

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    An abundance of loose threads pervades the international tax landscape as the first year of the global minimum tax unfolds, with the battle over digital services taxes still smoldering and diplomats talking tougher taxes on the wealthy. Here, Law360 looks at international tax policy to watch in the second half of 2024.

Expert Analysis

  • Lead Like 'Ted Lasso' By Embracing Cognitive Diversity

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    The Apple TV+ series “Ted Lasso” aptly illustrates how embracing cognitive diversity can be a winning strategy for teams, providing a useful lesson for law firms, which can benefit significantly from fresh, diverse perspectives and collaborative problem-solving, says Paul Manuele at PR Manuele Consulting.

  • Now More Than Ever, Lawyers Must Exhibit Professionalism

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    As society becomes increasingly fractured and workplace incivility is on the rise, attorneys must champion professionalism and lead by example, demonstrating how lawyers can respectfully disagree without being disagreeable, says Edward Casmere at Norton Rose.

  • Reading Between The Lines Of Justices' Moore Ruling

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    The U.S. Supreme Court's recent Moore v. U.S. decision, that the Internal Revenue Code Section 965 did not violate the 16th Amendment, was narrowly tailored to minimally disrupt existing tax regimes, but the justices' various opinions leave the door open to future tax challenges and provide clues for what the battles may look like, say Caroline Ngo and Le Chen at McDermott.

  • A Midyear Forecast: Tailwinds Expected For Atty Hourly Rates

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    Hourly rates for partners, associates and support staff continued to rise in the first half of this year, and this growth shows no signs of slowing for the rest of 2024 and into next year, driven in part by the return of mergers and acquisitions and the widespread adoption of artificial intelligence, says Chuck Chandler at Valeo Partners.

  • States Should Loosen Law Firm Ownership Restrictions

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    Despite growing buzz, normalized nonlawyer ownership of law firms is a distant prospect, so the legal community should focus first on liberalizing state restrictions on attorney and firm purchases of practices, which would bolster succession planning and improve access to justice, says Michael Di Gennaro at The Law Practice Exchange.

  • After Chevron: Uniform Tax Law Interpretation Not Guaranteed

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    The loss of Chevron deference will significantly alter the relationship between the IRS, courts and Congress when it comes to tax law, potentially precipitating more transparent rulemaking, but also provoking greater uncertainty due to variability in judicial interpretation, say Michelle Levin and Carneil Wilson at Dentons.

  • Texas Ethics Opinion Flags Hazards Of Unauthorized Practice

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    The Texas Professional Ethics Committee's recently issued proposed opinion finding that in-house counsel providing legal services to the company's clients constitutes the unauthorized practice of law is a valuable clarification given that a UPL violation — a misdemeanor in most states — carries high stakes, say Hilary Gerzhoy and Julienne Pasichow at HWG.

  • How To Clean Up Your Generative AI-Produced Legal Drafts

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    As law firms increasingly rely on generative artificial intelligence tools to produce legal text, attorneys should be on guard for the overuse of cohesive devices in initial drafts, and consider a few editing pointers to clean up AI’s repetitive and choppy outputs, says Ivy Grey at WordRake.

  • Industry Self-Regulation Will Shine Post-Chevron

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    The U.S. Supreme Court's Loper decision will shape the contours of industry self-regulation in the years to come, providing opportunities for this often-misunderstood practice, says Eric Reicin at BBB National Programs.

  • 3 Ways Agencies Will Keep Making Law After Chevron

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    The U.S. Supreme Court clearly thinks it has done something big in overturning the Chevron precedent that had given deference to agencies' statutory interpretations, but regulated parties have to consider how agencies retain significant power to shape the law and its meaning, say attorneys at K&L Gates.

  • Atty Well-Being Efforts Ignore Root Causes Of The Problem

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    The legal industry is engaged in a critical conversation about lawyers' mental health, but current attorney well-being programs primarily focus on helping lawyers cope with the stress of excessive workloads, instead of examining whether this work culture is even fundamentally compatible with lawyer well-being, says Jonathan Baum at Avenir Guild.

  • Unpacking The Circuit Split Over A Federal Atty Fee Rule

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    Federal circuit courts that have addressed Rule 41(d) of the Federal Rules of Civil Procedure are split as to whether attorney fees are included as part of the costs of a previously dismissed action, so practitioners aiming to recover or avoid fees should tailor arguments to the appropriate court, says Joseph Myles and Lionel Lavenue at Finnegan.

  • After A Brief Hiccup, The 'Rocket Docket' Soars Back To No. 1

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    The Eastern District of Virginia’s precipitous 2022 fall from its storied rocket docket status appears to have been a temporary aberration, as recent statistics reveal that the court is once again back on top as the fastest federal civil trial court in the nation, says Robert Tata at Hunton.