International

  • September 23, 2024

    The Tax Angle: Corporate Inversions, SALT Cap

    From a look at criticisms that the 2017 federal tax law failed to stop corporations from moving overseas to GOP efforts to navigate the SALT cap ahead of the November elections, here's a peek into a reporter's notebook on a few of the week's developing tax stories.

  • September 23, 2024

    Sysco Allowed $324M Dividend Deduction After Varian Ruling

    Sysco Corp. can deduct $324 million in foreign dividends after agreeing with the Internal Revenue Service that a decision in a similar case brought by Varian Medical Systems resolved their dispute, the U.S. Tax Court said in an order.

  • September 23, 2024

    Disney Asks Justices To Review NY Tax On Foreign Royalties

    New York's highest court used the wrong standard for evaluating tax statutes for discrimination when it denied deductions that The Walt Disney Co. sought for royalties received from foreign affiliates, the company argued in a petition to the U.S. Supreme Court that Law360 obtained Monday.

  • September 23, 2024

    Singapore Man Sentenced To 4 Years In $43M Fraud Scheme

    A Singapore man involved in a scheme that made SG$55 million ($43 million) in fictitious sales that resulted in more than SG$7.5 million in fraudulent goods-and-services tax, or GST, refund claims was sentenced to more than four years in prison Monday, the country's revenue authority said.

  • September 23, 2024

    IRS Finalizing Pricing Pact Guidance, Official Says

    The Internal Revenue Service is in the final stages of updating revenue procedures to help multinational corporations pursue advance pricing agreements and resolve tax treaty disputes, and it will release the guidance soon, an agency official said Monday.

  • September 23, 2024

    Irish Carbon Tax Could Generate €8.8B By 2030, Report Says

    Planned rate increases and other factors could see Ireland's carbon tax generate at least €8.8 billion ($9.8 billion) in revenue over the next six years, compared with over €3.3 billion generated from 2019 through 2023, the country's Financial Services Division said.

  • September 23, 2024

    Squire Patton Tax Ace Joins Winston & Strawn In Dallas

    Winston & Strawn LLP announced Monday it has expanded its tax offerings with the addition of an experienced attorney from Squire Patton Boggs LLP in Texas.

  • September 23, 2024

    HMRC Raises £1B Cracking Down On Tax Fraud

    HM Revenue & Customs raised almost £1 billion ($1.3 billion) in its most serious criminal investigations of tax fraud year-on-year in April, according to research published by a law firm Monday.

  • September 23, 2024

    Belgium Has High Tax Burden, Public Debt, OECD Says

    While there are some tax changes Belgium should consider, the country should tackle its high public debt through better spending practices because its tax burden is among the highest in the OECD, the organization said Monday.

  • September 23, 2024

    Pension Experts Urge Tax Breaks For UK Investment Plan

    The government could best encourage investment in the economy from pension schemes by adopting tax incentives, a trade body said.

  • September 20, 2024

    8th Circ. To Hear Args In 3M's $24M Tax Case Next Month

    The Eighth Circuit said Friday that it will hear oral arguments next month in 3M's transfer pricing appeal, in which the multinational conglomerate is challenging the Internal Revenue Service's authority to reallocate to the company $24 million from a Brazilian affiliate.

  • September 20, 2024

    IRS Special Trial Attorney Joins Hochman Salkin In California

    When Hochman Salkin Toscher Perez PC's newest principal, Sebastian Voth, was studying at Emory University School of Law, a former chief counsel for the Internal Revenue Service told students that the IRS was a great place to start their careers. After 15 years as an IRS attorney, Voth found that the agency was also a great place to work, he told Law360 Pulse in an interview Friday.

  • September 20, 2024

    Australia Seeks Comments On Luxury Car Tax Green Changes

    Australia is looking for comments on plans to adjust the country's luxury car tax to update the definition of a fuel-efficient car and to make changes to the way the tax threshold is indexed, the country's Treasury Department said Friday.

  • September 20, 2024

    Hong Kong's Tax Revenue Drops For 2nd Straight Year

    Hong Kong's tax revenue dipped by HK$14 billion ($1.8 billion) to HK$342 billion in the 2023-24 tax year — the second straight year with a drop — largely because of decreases in stamp duty and profit tax collections, its tax authority said Friday.

  • September 20, 2024

    Taxation With Representation: Gibson Dunn, Holland & Knight

    In this week's Taxation With Representation, CACI International buys Azure Summit Technology, Hotel Engine lands a valuation led by Permira, and Knowles Corp. sells its microphone business to Syntiant Corp.

  • September 20, 2024

    UK Budget May Seek Gains From Inheritance Tax, Firms Say

    The U.K. government may try to squeeze more revenue out of the wealthy via inheritance tax, wealth management firms said Friday following the release of data showing the levy is generating higher returns for HM Treasury.

  • September 19, 2024

    Pillar 1's Safe Harbor Limits Split Of Taxing Rights, Study Says

    The redistribution of corporate taxing rights among countries that agreed to new profit reallocation rules known as Pillar One would be "seriously affected" by a proposed safe harbor, according to report from a think tank funded by the European Union.

  • September 19, 2024

    Death Doesn't Preclude FBAR Penalties, Judge Says

    The death of a U.S. citizen who failed to file reports of foreign bank and financial accounts doesn't stop the U.S. government from enforcing penalties against his estate, a New York federal judge ruled.

  • September 19, 2024

    Spain Tax Inspections Generated €16.7B In Revenue In 2023

    Spain's tax agency said Thursday that it increased the number of control actions it took against large companies and other groups by nearly 14% in 2023 as part of the agency's €16.7 billion ($18.6 billion) in revenue generated from control work last year.

  • September 19, 2024

    Sweden Aiming For Broad Tax Cuts In 2025 Budget

    Swedish taxpayers would see lower tax rates in many areas, such as on their labor and pensions, as part of a proposed 2025 budget that the government sent to the country's legislature for consideration Thursday.

  • September 19, 2024

    EU, China Fail To End EV Dispute But Talks Continue

    Negotiators from the European Union and China failed to resolve a dispute over EU antisubsidy tariffs on imported electric vehicles from China but promised Thursday to intensify efforts to find a mutually agreeable solution.

  • September 19, 2024

    Nine Countries Sign Treaty For OECD Min. Tax On Payments

    Indonesia, Turkey, Congo and six other countries signed a multilateral treaty aimed at implementing a 9% minimum tax on income sent from their jurisdictions to low-taxed entities within a corporate group, the OECD said Thursday.

  • September 19, 2024

    EU Top Court Rules UK's CFC Tax Breaks Not State Aid

    The European Court of Justice ruled Thursday that tax breaks the U.K. gave to certain companies under controlled foreign company regulations did not breach European Union state aid law.

  • September 19, 2024

    Apple Ruling Prompts EU Lawmakers To Call For Tax Justice

    Citing the recent European court judgment requiring Apple to pay €13 billion ($14.5 billion) in taxes to Ireland, European Union lawmakers demanded Thursday that the fight against tax evasion and for corporate tax harmonization be stepped up.

  • September 19, 2024

    EU Wrong To Block Berlusconi's Bank Stake, Top Court Rules

    Europe's highest court ruled Thursday that the European Central Bank was wrong to decide that a prior conviction for tax fraud prevented former Italian Prime Minister Silvio Berlusconi from holding a stake in a bank in the country.

Expert Analysis

  • Legal Profession Gender Parity Requires Equal Parental Leave

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    To truly foster equity in the legal profession and to promote attorney retention, workplaces need to better support all parents, regardless of gender — starting by offering equal and robust parental leave to both birthing and non-birthing parents, says Ali Spindler at Irwin Fritchie.

  • A Year-End Look At Florida's Capital Investment Tax Credit

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    Notwithstanding the Walt Disney Co.’s feud with Gov. Ron DeSantis this year, Florida's capital investment tax credit will continue to make the state a favored destination for large corporations, particularly in light of the new federal alternative minimum tax and the Pillar Two top-up tax, says Alan Lederman at Gunster.

  • Understanding Discovery Obligations In Era Of Generative AI

    Excerpt from Practical Guidance
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    Attorneys and businesses must adapt to the unique discovery challenges presented by generative artificial intelligence, such as chatbot content and prompts, while upholding the principles of fairness, transparency and compliance with legal obligations in federal civil litigation, say attorneys at King & Spalding.

  • The Case For Post-Bar Clerk Training Programs At Law Firms

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    In today's competitive legal hiring market, an intentionally designed training program for law school graduates awaiting bar admission can be an effective way of creating a pipeline of qualified candidates, says Brent Daub at Gilson Daub.

  • AI Can Help Lawyers Overcome The Programming Barrier

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    Legal professionals without programming expertise can use generative artificial intelligence to harness the power of automation and other technology solutions to streamline their work, without the steep learning curve traditionally associated with coding, says George Zalepa at Greenberg Traurig.

  • Preparing Law Students For A New, AI-Assisted Legal World

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    As artificial intelligence rapidly transforms the legal landscape, law schools must integrate technology and curricula that address AI’s innate challenges — from ethics to data security — to help students stay ahead of the curve, say Daniel Garrie at Law & Forensics, Ryan Abbott at JAMS and Karen Silverman at Cantellus Group.

  • General Counsel Need Data Literacy To Keep Up With AI

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    With the rise of accessible and powerful generative artificial intelligence solutions, it is imperative for general counsel to understand the use and application of data for myriad important activities, from evaluating the e-discovery process to monitoring compliance analytics and more, says Colin Levy at Malbek.

  • Navigating Discovery Of Generative AI Information

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    As generative artificial intelligence tools become increasingly ubiquitous, companies must make sure to preserve generative AI data when there is reasonable expectation of litigation, and to include transcripts in litigation hold notices, as they may be relevant to discovery requests, say Nick Peterson and Corey Hauser at Wiley.

  • Finding Focus: Strategies For Attorneys With ADHD

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    Given the prevalence of ADHD among attorneys, it is imperative that the legal community gain a better understanding of how ADHD affects well-being, and that resources and strategies exist for attorneys with this disability to manage their symptoms and achieve success, say Casey Dixon at Dixon Life Coaching and Krista Larson at Stinson.

  • Attorneys, Law Schools Must Adapt To New Era Of Evidence

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    Technological advancements mean more direct evidence is being created than ever before, and attorneys as well as law schools must modify their methods to account for new challenges in how this evidence is collected and used to try cases, says Reuben Guttman at Guttman Buschner.

  • 1st Tax Easement Convictions Will Likely Embolden DOJ, IRS

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    After recent convictions in the first criminal tax fraud trial over allegedly abusive syndicated conservation easements, the IRS and U.S. Department of Justice will likely pursue other promoters for similar alleged conspiracies — though one acquittal may help attorneys better evaluate their clients' exposure, say Bill Curtis and Lauren DeSantis-Then at Polsinelli.

  • Tips For Litigating Against Pro Se Parties In Complex Disputes

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    Litigating against self-represented parties in complex cases can pose unique challenges for attorneys, but for the most part, it requires the same skills that are useful in other cases — from documenting everything to understanding one’s ethical duties, says Bryan Ketroser at Alto Litigation.

  • Anticipating Intensified Partnership Enforcement From IRS

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    The Internal Revenue Service's decadeslong difficulties with partnership audits led to the recent announcement of a clear, well-funded, focused initiative, and businesses operating in the partnership form will feel the impact, with definite changes ahead, says Sharon Katz-Pearlman at Greenberg Traurig.

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