International
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February 26, 2025
Capital Gains Tax Breaks Lack Proof Of Growth, OECD Says
There is little to no empirical evidence to support the position adopted across most OECD governments that tax relief for capital gains leads to stronger economic growth, broader entrepreneurship and higher savings, the organization said in a report published Wednesday.
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February 26, 2025
Billionaire Claims HMRC Failed To Hold Lawful Tax Inquiry
HM Revenue & Customs failed to lawfully notify the right people in its investigation of tax returns for two partnerships, counsel for a hedge fund billionaire told a London court Wednesday.
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February 26, 2025
ATO Moving Fast Against Outlier Tax Debtors, Chief Says
The Australian Taxation Office is "moving harder and faster" to collect from the 1% of tax debtors who owe about a fifth of the country's roughly AU$50 billion ($31.5 billion) in tax debts, according to prepared remarks by the country's tax commissioner for lawmakers Wednesday.
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February 26, 2025
Coke's $2.7B Tax Bill Due To 'Bait And Switch,' 11th Circ. Told
Coca-Cola urged the Eleventh Circuit to reverse a U.S. Tax Court decision putting the beverage giant on the hook for $2.7 billion in taxes, arguing the ruling excused the IRS' "blatant bait and switch" regarding how it allocates income from foreign affiliates.
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February 26, 2025
Tax Overhaul Designer Named Top Tax Adviser To Treasury
An attorney who worked for Exxon Mobil and helped design the 2017 tax overhaul in President Donald Trump's first term has been appointed to serve as a top tax adviser to Treasury Secretary Scott Bessent, Treasury announced Wednesday.
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February 25, 2025
Promised German Tax Cuts Could Come As Deficit Climbs
With the Christian Democrats, winners of Germany's election, having promised to pursue tax cuts, the country's Ministry of Finance revealed Tuesday that the budget deficit reached €18.7 billion ($19.7 billion) last month.
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February 25, 2025
Canada Seeking Feedback On EV Supply Chain Tax Credit
Canada's government is looking for public input on a plan to introduce a tax credit designed to help support the expansion of electric vehicle manufacturing.
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February 25, 2025
Brazil Starts Corp. Tax Compliance Benefit Program
Companies in Brazil that are up to date and compliant with their tax obligations will be offered benefits for doing so as part of a pilot program, the country's tax service said.
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February 24, 2025
Eaton's Foreign Tax Credits Rejected By Tax Court
The U.S. Tax Court rejected foreign tax credits that Eaton Corp. had claimed on its lower-tier overseas entities' income taxes for 2007 and 2008, saying in a Monday opinion that its overseas ownership structure had disqualified the multinational power management company.
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February 24, 2025
Investor Settles In $2.1B Danish Tax Fraud Case
A U.S. investor who was among those accused by Denmark's tax agency of participating in a $2.1 billion tax fraud scheme related to fraudulently claiming refunds on tax withheld from stock dividends has reached a settlement, according to New York federal court documents filed Monday.
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February 24, 2025
Denmark Argues Misrepresentation Led To £1.4B Tax Refunds
Denmark's tax authority told the High Court of Justice on Monday that it would not have paid out billions in refunds to a British trader and others accused of involvement in a fraudulent trading scheme had they not submitted forms purporting to show eligibility for tax refunds.
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February 24, 2025
Ex-Goldman Exec Owes For Not Filing FBARs, US Says
A former Goldman Sachs banking executive who lives in Australia owes penalties to the Internal Revenue Service for failing to report foreign bank accounts she held, the U.S. government told a D.C. federal court.
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February 24, 2025
NZ Reviewing Charity Business Income Tax Exemption
New Zealand is looking for comments on its internationally unique tax structure that allows charities and not-for-profits to conduct business activities tax-free in order to raise money, asking stakeholders whether such a regime continues to be effective, the country's tax agency said Monday.
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February 24, 2025
Apple To Invest $500B In US Over 4 Years As Tariffs Mount
Apple said Monday that it would invest $500 billion in the U.S. over the next four years, weeks after President Donald Trump placed a 10% tariff on goods from China, where the company sources components for its products, and threatened tariffs on semiconductors.
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February 24, 2025
Aussie Tax Office Agrees To Step Up Safeguards For AI
The Australian Taxation Office said Monday that it will implement seven recommendations made by a national auditing body regarding the agency's adoption of artificial intelligence tools, including looking closer at potential data ethics risks and the overall development of the programs.
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February 24, 2025
High Court Won't Hear Tax Tipster's $690M Award Claim
The U.S. Supreme Court declined on Monday to review a man's claim for a $690 million whistleblower award for undercover recordings and tips he gave the IRS that he said led to the arrests of Swiss bankers and the success of an offshore tax disclosure program.
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February 24, 2025
OECD Issues Consolidated Guidance On Amount B
The OECD issued consolidated guidance Monday that it put out throughout last year for an internationally agreed-upon method to apply the arm's-length principle to pricing baseline marketing and distribution activities by multinational corporations, known as Amount B of Pillar One.
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February 21, 2025
Trump Says Tariffs Coming For Countries With DSTs
President Donald Trump's administration will impose tariffs on countries with taxes that disproportionately affect American companies, such as digital services taxes, which mainly apply to tech giants, according to a memorandum released late Friday.
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February 21, 2025
The Tax Angle: ABA Midyear Tax Meeting
With a lack of government officials attending the American Bar Association's midyear tax meeting, here's a peek into a reporter's notebook on a few of the week's developing tax stories.
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February 21, 2025
China Says Tax Deferral Boosted Foreign Reinvestment
A tax regime exempting foreign investors from withholding taxes on certain profits generated by their China-based businesses as long as those profits are directly reinvested in projects in China led to a 15% year-over-year increase in foreign reinvestment, the country's tax administration said Friday.
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February 21, 2025
French 2% Minimum Wealth Tax Advances In Parliament
French households with assets worth more than €100 million ($104.6 million) would be subject to a 2% minimum tax on their net worth annually under a top-up wealth tax proposal approved by the lower house of France's Parliament.
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February 21, 2025
IRS, Engineer Resolve Fight Over $5.5M In FBAR Penalties
The U.S. government and an engineer have resolved a dispute over $5.5 million in penalties and interest regarding the nondisclosure of assets in her foreign accounts from 2009 to 2012, according to a judgment entered by a California federal court.
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February 21, 2025
Australia Lays Out Eligibility For Hydrogen, Mineral Credits
The Australian Taxation Office released guidance for companies hoping to claim either of a pair of new tax incentives aimed at hydrogen and critical mineral production, including eligibility requirements and how to claim the credits.
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February 21, 2025
DLA Piper Tax Attorney Jumps To Vedder Price In Chicago
Vedder Price PC has expanded its Chicago office with the addition of a skilled tax attorney who brings nearly 30 years of experience, most recently with DLA Piper.
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February 21, 2025
Taxation With Representation: Kirkland, V&E, Cravath, Dechert
In this week's Taxation With Representation, Diamondback Energy buys Midland Basin assets from another oil and natural gas company, GTCR closes its second strategic growth fund, Light & Wonder Inc. buys Grover Gaming's assets, and Barings acquires Artemis Real Estate Partners.
Expert Analysis
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Judicial Committee Best Venue For Litigation Funding Rules
The Advisory Committee on Civil Rules' recent decision to consider developing a rule for litigation funding disclosure is a welcome development, ensuring that the result will be the product of a thorough, inclusive and deliberative process that appropriately balances all interests, says Stewart Ackerly at Statera Capital.
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The Strategic Advantages Of Appointing A Law Firm CEO
The impact on law firms of the recent CrowdStrike outage underscores that the business of law is no longer merely about providing supplemental support for legal practice — and helps explain why some law firms are appointing dedicated, full-time CEOs to navigate the challenges of the modern legal landscape, says Jennifer Johnson at Calibrate Strategies.
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How Cos. Can Build A Strong In-House Pro Bono Program
During this year’s pro bono celebration week, companies should consider some key pointers to grow and maintain a vibrant in-house program for attorneys to provide free legal services for the public good, says Mary Benton at Alston & Bird.
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Home Canning Makes Me A Better Lawyer
Making my own pickles and jams requires seeing a process through from start to finish, as does representing clients from the start of a dispute at the Patent Trial and Appeal Board through any appeals to the Federal Circuit, says attorney Kevin McNish.
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Use The Right Kind Of Feedback To Help Gen Z Attorneys
Generation Z associates bring unique perspectives and expectations to the workplace, so it’s imperative that supervising attorneys adapt their feedback approach in order to help young lawyers learn and grow — which is good for law firms, too, says Rachael Bosch at Fringe Professional Development.
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Congress Can And Must Enact A Supreme Court Ethics Code
As public confidence in the U.S. Supreme Court dips to historic lows following reports raising conflict of interest concerns, Congress must exercise its constitutional power to enact a mandatory and enforceable code of ethics for the high court, says Muhammad Faridi, president of the New York City Bar Association.
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What To Make Of Dueling Corporate Transparency Act Rulings
Although challenges to the Corporate Transparency Act abound — as highlighted by recent federal court decisions from Alabama and Oregon taking opposite positions on its constitutionality — the act is still law, so companies should comply with their filing requirements or face the potential consequences, say attorneys at Lowenstein Sandler.
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The Pop Culture Docket: Justice Lebovits On Gilbert And Sullivan
Characters in the 19th century comic operas of Gilbert and Sullivan break the rules of good lawyering by shamelessly throwing responsible critical thought to the wind, providing hilarious lessons for lawyers and judges on how to avoid a surfeit of traps and tribulations, say acting New York Supreme Court Justice Gerald Lebovits and law student Tara Scown.
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State Of The States' AI Legal Ethics Landscape
Over the past year, several state bar associations, as well as the American Bar Association, have released guidance on the ethical use of artificial intelligence in legal practice, all of which share overarching themes and some nuanced differences, say Eric Pacifici and Kevin Henderson at SMB Law Group.
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8 Childhood Lessons That Can Help You Be A Better Attorney
A new school year is underway, marking a fitting time for attorneys to reflect on some fundamental life lessons from early childhood that offer a framework for problems that no legal textbook can solve, say Chris Gismondi and Chris Campbell at DLA Piper.
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This Election, We Need To Talk About Court Process
In recent decades, the U.S. Supreme Court has markedly transformed judicial processes — from summary judgment standards to notice pleadings — which has, in turn, affected individuals’ substantive rights, and we need to consider how the upcoming presidential election may continue this pattern, says Reuben Guttman at Guttman Buschner.
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Mental Health First Aid: A Brief Primer For Attorneys
Amid a growing body of research finding that attorneys face higher rates of mental illness than the general population, firms should consider setting up mental health first aid training programs to help lawyers assess mental health challenges in their colleagues and intervene with compassion, say psychologists Shawn Healy and Tracey Meyers.
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The Trade And Tax Issues Behind US-Canada Digital Tax Clash
The new Canadian digital services tax recently went into effect despite objections from the U.S., a controversy that represents an unusual mix of trade and tax policy, and many companies have been pondering how it will affect their e-commerce businesses, says Damon Pike at BDO.