International
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January 16, 2025
Treasury Updates Bonus Energy Tax Credit Safe Harbors
The U.S. Treasury Department provided updates Thursday to safe harbors that clean energy project developers can use to qualify for bonus tax credits for domestically sourcing steel and aluminum parts in response to new trade restrictions on solar products from China by President Joe Biden's administration.
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January 15, 2025
Dems, GOP Willing To Work On Certain Tax Issues, Aides Say
Democrats are willing to work with Republicans on bipartisan issues, such as providing certain treaty-like benefits to Taiwanese residents, retirement issues, and tax administration issues, Democratic and GOP aides for the House Ways and Means and Senate Finance committees said Wednesday.
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January 15, 2025
Former IRS Litigator Joins Jones Day In Boston
Jones Day announced it added an experienced IRS litigator to its Boston office who will work as of counsel in the firm's tax practice.
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January 15, 2025
Legislators Say Transparency Act Defies First Amendment
The Corporate Transparency Act is an unnecessary intrusion into the First Amendment rights of Americans, U.S. Sen. Thom Tillis, R-N.C., and 13 House members told the Supreme Court in seeking to maintain an injunction issued in December.
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January 15, 2025
House Clears US-Taiwan Double Tax Relief Bill
The U.S. House of Representatives overwhelmingly approved legislation Wednesday that would provide Taiwanese businesses in the United States with tax-treaty-like benefits and authorize the White House to negotiate a tax agreement with Taiwan.
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January 15, 2025
Australia Gives Guidance On Foreign-Funded Construction
The Australian Taxation Office laid out a number of key areas that private companies receiving foreign funding from a related party for property or construction projects need to be aware of in order to not run afoul of the country's transfer pricing rules.
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January 15, 2025
HMRC Board Chair Calls Fiscal Rules Nonnegotiable
The U.K. government will not change course on its fiscal rules despite higher borrowing costs from worsening market conditions, the chair of the board of Britain's tax authority told Parliament's Treasury Committee on Wednesday.
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January 15, 2025
Sweden Should Expand, Simplify R&D Tax Credit, Report Says
A government report said Sweden should simplify and expand its research and development tax credit regime and make changes to what is known as its expert tax incentives in order to improve the country's competition and productivity, its Ministry of Finance said Wednesday.
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January 15, 2025
IRS Mulling Widened Early Application Of Offshore Profit Regs
The Internal Revenue Service is considering expanding the early application option for proposed regulations designed to help U.S. multinational corporations properly account for previously taxed earnings and profits, an agency official said Wednesday.
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January 15, 2025
Chile Must Increase Tax Revenue To Cut Into Debt, OECD Says
With Chile's tax revenues making up just 21% of its gross-domestic product, the country needs to boost its revenue through broad changes to its tax regime if it hopes to keep up with rising spending needs, the Organization for Economic Cooperation and Development said Wednesday.
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January 15, 2025
30 Countries' Minimum Taxes Pass First Review, OECD Says
Policies in about 30 countries passed an initial review for compliance with the 15% global minimum tax system, the first batch to reach that milestone, the Organization for Economic Cooperation and Development said Wednesday.
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January 15, 2025
Netherlands Considering Long-Haul Flight Tax Increase
The Netherlands government is looking for feedback on a plan to replace its flat aviation tax with one that is distance-dependent in hopes of boosting revenue from the tax while encouraging more climate-friendly behaviors, the country's finance ministry said Wednesday.
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January 14, 2025
KPMG, Biz Groups, NY Tax Bar Urge Reg Fixes To Corp. AMT
Energy company and life insurance groups have proposed industry-specific adjustments to the U.S. corporate alternative minimum tax regulations, while the New York State Bar Association and KPMG advocate for simpler accounting methods to assess compliance, according to comment letters to the U.S. Treasury Department.
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January 14, 2025
Orrick Adds Paris Tax Partner From Latham
Orrick Herrington & Sutcliffe LLP added a former counsel at Latham & Watkins LLP as a partner in its Paris office, where she'll advise clients on the tax aspects of French and international transactions, the firm said.
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January 14, 2025
Spain Plans 100% Tax On Foreign-Owned Homes
The Spanish government plans to introduce a 100% tax on foreign-owned homes and stricter rules for holiday rentals to tourists, Prime Minister Pedro Sánchez said.
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January 14, 2025
Trump Announces Plans To Create 'External Revenue Service'
President-elect Donald Trump said Tuesday that he planned to create an "External Revenue Service" that would collect tariffs and revenue from foreign countries.
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January 13, 2025
IRS Puts Out Spinoff Rules, Multiyear Reporting Regime
The Internal Revenue Service released proposed regulations Monday for a narrow set of corporate separation transactions, known as spinoffs, that the agency will approve as tax-free ahead of time, alongside guidance detailing multiyear reporting requirements for those deals.
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January 13, 2025
PepsiCo Created Shell Co. To Avoid Taxes, Ill. Court Says
PepsiCo operated a shell company as part of a scheme that resulted in its Illinois income tax bill for its Frito-Lay unit being deficient nearly $10.9 million, a state circuit court ruled.
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January 13, 2025
AGs, Lobbyists Ask Justices To Keep Shell Co. Law Blocked
The U.S. Supreme Court should deny the federal government's emergency application to stay a Texas district court's injunction on a law aimed at cracking down on crimes committed with shell companies, according to numerous state attorneys general and interest groups and a handful of small businesses.
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January 13, 2025
Tax Firm Asks Court To Ax Final IRS Microcaptive Rules
A global tax services provider asked a Texas federal court to vacate finalized tax rules requiring the reporting of certain transactions involving captive insurance companies deemed as potentially abusive, arguing the guidance goes beyond the agency's authority.
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January 13, 2025
Sen. Warren To Grill Treasury Pick On Trump's Tax Agenda
Sen. Elizabeth Warren, D-Mass., plans to ask Treasury secretary nominee Scott Bessent at his confirmation hearing in front of the Senate Finance Committee on Thursday about President-elect Donald Trump's tax agenda and plans for the Internal Revenue Service, according to a letter she sent the nominee.
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January 13, 2025
The Tax Angle: GOP Lawmakers Grapple With TCJA Renewal
From a look at Congress setting parameters for consideration of legislation to renew the GOP's 2017 tax overhaul law to other upcoming tax action in the House and Senate, here's a peek into a reporter's notebook on a few of the week's developing tax stories.
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January 13, 2025
Norway Seeking Comments On Shareholder Register Plans
The Norway Tax Administration is looking for public comments on plans to introduce a shareholder register that it said would provide authorities with important ownership information, laying out four options for consideration but highlighting its preferred one, it said Monday.
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January 13, 2025
Pillar 2's Effect May Vary Based On Biz Function, Report Says
The global minimum tax deal known as Pillar Two may have a minimal effect on where multinational corporations carry out routine business functions, but companies could eventually change where they perform other operations, according to an OECD paper released Monday.
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January 13, 2025
Still No Unanimous Path Forward On Amount B, OECD Says
The Organization for Economic Cooperation and Development has still not found a path to an agreement on Pillar One's Amount B, which is designed to streamline the pricing of certain baseline marketing and distribution activities, with conversations being held up by possible "inappropriate outcomes," the OECD said Monday.
Expert Analysis
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Legal Profession Gender Parity Requires Equal Parental Leave
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.
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A Year-End Look At Florida's Capital Investment Tax Credit
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.
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Understanding Discovery Obligations In Era Of Generative AI
Excerpt from Practical Guidance
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.
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The Case For Post-Bar Clerk Training Programs At Law Firms
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.
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AI Can Help Lawyers Overcome The Programming Barrier
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.
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Preparing Law Students For A New, AI-Assisted Legal World
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.
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General Counsel Need Data Literacy To Keep Up With AI
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.
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Navigating Discovery Of Generative AI Information
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.
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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.