International
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October 11, 2024
Italian Police Freeze €12.3M In Textile VAT Fraud Investigation
The Italian Financial Police carried out two freezing orders totaling €12.3 million ($13.5 million) against suspects in an ongoing investigation into a value-added tax fraud involving the illegal importation of textiles from China, the European Public Prosecutor's Office said.
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October 11, 2024
Bird & Bird Adds DLA Piper Legal Director To London Office
Bird & Bird LLP has added a former DLA Piper legal director as a partner to its London tax team.
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October 11, 2024
Disputes May Loom Over Dividend Deductions For CFCs
U.S. multinational corporations are concerned that rulemakers' interpretation of a law allowing tax-free repatriation of certain overseas earnings could lead to controversy after the Internal Revenue Service published a memo indicating the break is unavailable for controlled foreign corporations.
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October 11, 2024
Fla. Businessman's Estate Faces $2.6M In FBAR Penalties
A Florida businessman's estate owes the federal government $2.6 million in penalties plus interest for his failure to report his Swiss bank account from 2013 to 2017, the government told a federal court.
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October 11, 2024
Taxation With Representation: Davis Polk, Latham, Kirkland
In this week's Taxation With Representation, Rio Tinto agrees to acquire Arcadium Lithium for roughly $6.7 billion, Ares Management Corp. and GCP International reach a $3.7 billion deal, and Butterfly Equity announces plans to buy The Duckhorn Portfolio for $2 billion.
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October 10, 2024
Ukraine's Parliament Hikes Taxes To Fund War With Russia
Ukraine's Parliament announced that it approved several amendments to the country's tax code Thursday that will raise revenues for its war with Russia.
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October 10, 2024
Pillar 2 Carveout Should Cover Some Mobile Items, NFTC Says
The exemption for tangible investments from the global minimum tax known as Pillar Two should include certain mobile assets, such as ships and aircraft, the National Foreign Trade Council recommended.
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October 10, 2024
Ryanair To Scale Back German Flights After Tax Hike
Irish discount airline Ryanair announced plans Thursday to follow through on its threat to cut back service to Germany next summer over tax issues, saying it will cut 12% of its total capacity in the country — equal to 1.8 million seats — and close three bases of operation.
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October 10, 2024
Pfizer Lone Holdout In Senate Pharma Tax Probe, Wyden Says
Pfizer Inc. is the only company to withhold a country-by-country breakdown of its tax planning in the Senate Finance Committee's probe into how Republicans' 2017 tax package reduced the pharmaceutical industry's U.S. liabilities, according to a letter Chairman Ron Wyden released Thursday.
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October 10, 2024
UK Exit Taxes OK When Paid Over Time, Upper Tribunal Says
An exit tax on U.K. trusts leaving the country pre-Brexit interfered with their European Union right to free movement of capital, but is brought into compliance if trusts can pay the tax over at least a five-year period, the Upper Tribunal ruled.
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October 10, 2024
Switzerland Reports Info Exchanges With 108 Jurisdictions
Switzerland's Federal Tax Administration has exchanged information on roughly 3.7 million financial accounts with 108 jurisdictions so far in 2024, the government said Thursday.
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October 10, 2024
Ireland's Finance Bill Sets Out Foreign Dividend Exemption
The Irish government set out its plans for a new participation tax exemption for foreign dividends as part of a finance bill published Thursday.
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October 10, 2024
Algeria Joins OECD Tax Transparency Treaty
Algeria formally joined the Organization for Economic Cooperation and Development's global tax transparency agreement on combating tax avoidance and evasion by multinational corporations, the OECD announced Thursday.
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October 09, 2024
Australia Floats Debt Reduction Creation Rules Guidance
The Australian Taxation Office published draft guidance Wednesday for the country's new debt deduction creation rules, including the planned compliance approach and a framework for risk assessment.
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October 09, 2024
European Parliament Backs Brazil's G20 Wealth Tax Plan
A majority of the European Parliament supports a 2% minimum tax on billionaires presented by Brazil at the Group of 20 nations meeting, asking the European Union to pursue the topic at the group's November summit, according to joint statements by members of Parliament on Wednesday.
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October 09, 2024
Swiss Council Rejects Funding Pensions With Transaction Tax
Switzerland should not use the revenue generated by its two taxes on financial market transactions to fund the country's pension fund, nor should it create new ones for that purpose, the Swiss Federal Council said Wednesday.
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October 09, 2024
OECD Should Clarify Pillar 2 Safe Harbor Timing, CPAs Say
The OECD should clarify when exactly multinational corporations need to determine whether they qualify for a transitional safe harbor under an international minimum tax agreement, the American Institute of Certified Public Accountants recommended in a letter.
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October 09, 2024
UK Gov't Greenlights Film Industry Tax Credit
U.K. film companies will be able to gain over 50% tax relief for their films' costs from a tax credit approved Wednesday by the Labour government.
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October 09, 2024
3M Tax Ruling Must Fall Post-Chevron, Chamber Tells 8th Circ.
The U.S. Supreme Court's ending of the Chevron doctrine calls for overturning a U.S. Tax Court ruling that let the IRS allocate $24 million of income to multinational conglomerate 3M from a Brazilian affiliate, the U.S. Chamber of Commerce told the Eighth Circuit on Wednesday.
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October 09, 2024
Starmer Refuses To Rule Out Payroll Tax Hike
Prime Minister Keir Starmer didn't rule out raising employers' National Insurance contributions, a payroll tax used to fund healthcare and state pensions, during Wednesday's question time.
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October 09, 2024
Election Uncertainty Hampers Companies' Tax Planning
With the November election approaching, businesses are bracing for the potential impact of two very different sets of tax policies, with the resulting uncertainty making long-term tax planning increasingly difficult.
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October 09, 2024
Australia Seeking Large Cos.'s Tax Execs For Advisory Board
The Australian Taxation Office is looking for executives in charge of taxes for the country's largest businesses to join an advisory group focused on improving the Australian taxation systems, the ATO said Wednesday.
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October 09, 2024
Final Treasury Rules Shut Off Inclusion For Repatriated IP
The U.S. Treasury Department adopted final rules Wednesday that shut off an annual income inclusion associated with intangibles for companies in certain situations that have transferred intellectual property back to the U.S. from overseas.
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October 09, 2024
Gov't Warned Over National Insurance Levy On Pensions
About half of U.K. employers would scale back the amount they pay into staff pensions to regulatory minimums if a new tax was applied to contributions, according to a survey by a trade group published Wednesday.
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October 08, 2024
Germany May Offer Tax Break For 'E-Fuel' Cars, Ministry Says
The German government will consider a motor vehicle tax exemption for cars running only on fuels manufactured with renewable energy, known as e-fuels-only vehicles, the German Ministry of Finance announced Tuesday.
Expert Analysis
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Finding Focus: Strategies For Attorneys With ADHD
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.
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Attorneys, Law Schools Must Adapt To New Era Of Evidence
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.
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1st Tax Easement Convictions Will Likely Embolden DOJ, IRS
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.
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Tips For Litigating Against Pro Se Parties In Complex Disputes
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.
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Anticipating Intensified Partnership Enforcement From IRS
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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Pro Bono Work Is Powerful Self-Help For Attorneys
Oct. 22-28 is Pro Bono Week, serving as a useful reminder that offering free legal help to the public can help attorneys expand their legal toolbox, forge community relationships and create human connections, despite the challenges of this kind of work, says Orlando Lopez at Culhane Meadows.
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The Pop Culture Docket: Judge Espinosa On 'Lincoln Lawyer'
The murder trials in Netflix’s “The Lincoln Lawyer” illustrate the stark contrast between the ethical high ground that fosters and maintains the criminal justice system's integrity, and the ethical abyss that can undermine it, with an important reminder for all legal practitioners, say Judge Adam Espinosa and Andrew Howard at the Colorado 2nd Judicial District Court.
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How And Why Your Firm Should Implement Fixed-Fee Billing
Amid rising burnout in the legal industry and client efforts to curtail spending, pivoting to a fixed-fee billing model may improve client-attorney relationships and offer lawyers financial, logistical and stress relief — while still maintaining profit margins, say Kevin Henderson and Eric Pacifici at SMB Law Group.
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How Law Firms Can Use Account-Based Marketing Strategies
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.
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Strategic Succession Planning At Law Firms Is Crucial
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.
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Maximizing Law Firm Profitability In Uncertain Times
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.
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5th Circ. Ruling Reminds Attys That CBP Can Search Devices
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.
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Enforcement Of International Tax Reporting Is Heating Up
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.