International

  • July 15, 2024

    EU's Top Court Asked To Rule On Refund Of VAT In Bulgaria

    A Bulgarian court asked the European Union's highest court to determine whether a company in the country can receive a refund of value-added tax paid for devices when the devices did not leave the territory of another EU country, a document published Monday said.

  • July 12, 2024

    Rising Star: Quinn Emanuel's Emily Au

    Emily Au of Quinn Emanuel Urquhart & Sullivan LLP has been the lead attorney on several high-profile cases, including a key case across the U.K. construction industry in terms of HMRC's Value-Added Tax policy, earning her a spot among the tax law practitioners under age 40 honored by Law360 as Rising Stars.

  • July 12, 2024

    Law360 Names 2024's Top Attorneys Under 40

    Law360 is pleased to announce the Rising Stars of 2024, our list of 158 attorneys under 40 whose legal accomplishments belie their age.

  • July 12, 2024

    Chevron's End Doesn't Bear On 3M's Case, IRS Tells 8th Circ.

    The U.S. Supreme Court's recent overturning of Chevron deference doesn't warrant a reversal of a U.S. Tax Court ruling in 3M Co.'s transfer pricing case, the Internal Revenue Service told the Eighth Circuit on Friday.

  • July 12, 2024

    Parliament Vote On Von Der Leyen's 2nd Term Coming July 18

    The European Parliament will vote July 18 whether to approve current European Commission President Ursula von der Leyen for a second five-year term, according to a document published Friday.

  • July 12, 2024

    Switzerland, Hungary Adding Anti-Abuse Clause To Tax Treaty

    Switzerland and Hungary moved on Friday to add to their double-taxation treaty an anti-abuse clause that prevents a person who is not a resident of either country from claiming the benefits of the treaty.

  • July 12, 2024

    European Tax Policy To Watch In The Second Half Of 2024

    Observers of European Union tax policy expect the EU to devote more attention to problems with existing tax legislation in the coming months as the introduction of major policy proposals takes a pause. Specialists also will be watching for progress on EU tax laws that remain stuck, and the bloc is likely to fill roles including tax commissioner. Here, Law360 examines key tax issues to watch for the remaining six months of the year.

  • July 12, 2024

    Taxation With Representation: Ropes & Gray, Cravath, Latham

    In this Week's Taxation with Representation, Paramount Global merges with Skydance Media, Devon Energy acquires Grayson Mill Energy's Williston Basin oil and gas business, Ryan acquires Altus Group Ltd.'s property tax business, and Bain Capital buys Envestnet Inc.

  • July 12, 2024

    Worried Companies Ask For Pillar 2 Simplification

    Multinational corporations are worried about what they see as the huge compliance burden imposed by the global 15% minimum tax and are asking for permanent simplifications of the rules, two corporate tax officials said Friday.

  • July 12, 2024

    Alvarez & Marsal Appoints Managing Director Of Tax Group

    Alvarez & Marsal Tax LLC appointed an experienced negotiator of tax incentives as managing director to the firm's corporate transformation tax group, the firm announced.

  • July 12, 2024

    EU Chair Doesn't Expect Energy Tax Deal This Year

    The new chair of European Union finance ministers doesn't expect to reach agreement on a landmark energy taxation law in the next half-year, anticipating only exploratory talks, an official from Hungary's EU presidency said Friday.

  • July 11, 2024

    House GOP Urges USTR To Probe Canada Digital Services Tax

    The U.S. trade representative should immediately launch an investigation into Canada's recently enacted digital services tax and determine if trade actions are necessary to protect American interests, U.S. House Ways and Means Republicans said in a letter Thursday.

  • July 11, 2024

    ABA Attys Seek To Avoid Reporting Foreign Trust Loans

    The American Bar Association's tax, real estate and trust attorneys are seeking to prevent the U.S. Treasury Department from tightening reporting requirements for the exemption of loans from foreign trusts, which are often used by wealthy families and in succession planning, according to a consultation response.

  • July 11, 2024

    Brazilian Tax Agency Probes Refund Fraud Scheme

    Brazilian federal tax authorities and police said Thursday they had conducted a search-and-seizure operation related to the investigation of an income tax refund fraud scheme.

  • July 11, 2024

    Ex-Leaders Ask Biden For Int'l Coordination On Billionaire Tax

    President Joe Biden should get behind Brazil's proposal for the Group of 20 nations to coordinate a minimum tax on billionaires, nearly 20 former presidents and prime ministers from countries such as Canada, France and South Korea said in an open letter.

  • July 11, 2024

    IRS Proposes 'Basket Contracts' As Listed Transactions

    The Internal Revenue Service proposed rules Thursday that would flag so-called basket option contracts as potentially abusive listed transactions, imposing additional reporting requirements under the threat of penalty for individuals and businesses involved in such arrangements.

  • July 11, 2024

    IRS, OECD Officials Detail Expansion Of AI In Tax Work

    The Internal Revenue Service and Organization for Economic Cooperation and Development are making great progress in adopting artificial intelligence in tax administration, representatives of both organizations said Thursday.

  • July 11, 2024

    Israel Says Resident Hid $5.5M In Offshore Bank Accounts

    An Israeli resident was released under restrictive conditions Thursday after the government alleged he failed to report foreign bank accounts that held more than 20 million shekels ($5.5 million), according to a statement from the Israel Tax Authority.

  • July 11, 2024

    Tax Haven Biz Revenues Per Worker Still Far Outpace Norm

    Companies recorded median revenues per employee of $1.6 million in low-tax jurisdictions like Ireland, the Cayman Islands and Hong Kong and around $300,000 in all other jurisdictions in 2021, a difference that has narrowed since 2017, the OECD said Thursday.

  • July 11, 2024

    Biz Officials Call For Simpler Tax Rules In Light Of Pillar 2

    Business representatives said Thursday that tax compliance rules need to be simplified as new minimum tax rules, known as Pillar Two, are added to the existing regime.

  • July 11, 2024

    Failure Of Pillar 1 Would Yield Worse Alternatives, Panel Says

    A failure of the Pillar One agreement to reallocate corporate taxing rights would lead to alternatives that are worse, with the return of national digital services taxes worldwide, tax officials and academics said Thursday.

  • July 10, 2024

    Engineer Who Faced Export Charges Cops To Tax Counts

    A Chinese-born engineer has pled guilty to two counts of filing a false tax return related to allegations that he and his wife omitted gross income from their tax returns between 2015 and 2019, after Texas federal prosecutors initially charged the couple with export violations and fraud. 

  • July 10, 2024

    Portugal Enacts Pillar 2 As Part Of Economic, Tax Package

    Portugal's Council of Ministers approved the minimum tax provision known as Pillar Two in a package of economic and tax measures designed to boost the country's economic growth, the council announced.

  • July 10, 2024

    OECD Publishes Pillar 2 Technical Reporting Language Draft

    The Organization for Economic Cooperation and Development published a draft of technical details required to digitally input and disseminate information required for Pillar Two global minimum tax returns Wednesday.

  • July 10, 2024

    Americans Overseas Ask for Clarity In Foreign Trust Regs

    An advocacy group representing U.S. citizens living abroad urged the U.S. Treasury Department to clarify proposed rules for reporting transactions with foreign trusts, contending that guidance should explain which common pension arrangements are exempt from disclosure obligations.  

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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