International
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October 22, 2024
8th Circ. Judge Presses IRS On 3M Transfer Pricing Tax Ruling
An Eighth Circuit judge cast doubt during oral arguments Tuesday on the government's interpretation of regulations the IRS relied on to reallocate almost $24 million of income to 3M from its Brazilian affiliate that was subject to legal restrictions on royalty payments.
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October 22, 2024
New IRS Unit Starts Work On Pass-Through Compliance
A new Internal Revenue Service unit focused on the compliance of pass-through entities of all sizes and forms, such as partnerships, S corporations and trusts, has officially started work, the agency said Tuesday.
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October 22, 2024
Brazil Eyes Shifting Talks On Wealth Taxation To UN
Brazil is campaigning for the United Nations to commit to creating a minimum tax on high-net-worth individuals in February during expected talks on the organization's burgeoning global tax convention, a Brazilian finance ministry official said Tuesday at the International Monetary Fund.
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October 22, 2024
Argentina President Dissolving, Replacing Tax Agency
Argentina's tax authority, the Federal Public Revenue Administration, will be dissolved and replaced with a new body, the country's president said, with the change causing a 34% reduction in jobs.
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October 22, 2024
Tax Court Says It Can't Rule On FBAR Challenge
The U.S. Tax Court said Tuesday that it lacks the authority to rule on a couple's claim that the Internal Revenue Service wrongly denied them a chance to challenge penalties for failing to report their foreign bank accounts.
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October 22, 2024
Wafer Factories Qualify For CHIPS Tax Credit In Final Regs
Semiconductor wafer production facilities will qualify for the 25% investment tax credit that incentivizes advanced chip manufacturing development projects under final regulations the U.S. Department of the Treasury released Tuesday.
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October 22, 2024
IRS Working On Proposed Spinoff Rules, Agency Official Says
The Internal Revenue Service is planning to propose regulations that may amend positions in an existing revenue procedure that narrowed the range of spinoff transactions the agency will approve as tax-free ahead of time, an IRS official said Tuesday.
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October 22, 2024
Winston & Strawn Boosts Transactions Team With NY Tax Atty
As Winston & Strawn LLP continues to build out its transactions team, the firm has hired a new attorney from Hunton Andrews Kurth LLP with a focus on the tax aspects of real estate financing.
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October 22, 2024
Ireland Deposits €4B In Fund Set Up For Tax Surplus
Ireland transferred €4.05 billion ($4.4 billion) from its Exchequer to one of the sovereign wealth funds it created to invest surplus revenue generated by what the country's Department of Finance has characterized as volatile corporate tax receipts, the department said Tuesday.
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October 22, 2024
Portuguese Parliament Passes Min. Tax After EU Pressure
Portugal would implement the global corporate minimum tax spearheaded by the Organization for Economic Cooperation and Development under legislation sent to the country's president for approval Tuesday after the European Union put the country on notice for not adopting the tax.
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October 22, 2024
How Law Firms Get And Keep Elite Status
For decades, a handful of New York-based law firms thoroughly dominated the national consciousness when it came to power, profitability and prestige. But in today's legal market, increased movement of partners and clients from one firm to the next has begun to shake things up and create opportunities for go-getters to ascend the ranks.
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October 22, 2024
The 2024 Prestige Leaders
Check out our Prestige Leaders ranking, analysis and interactive graphics to see which firms stand out for their financial performance, attractiveness to attorneys and law students, ability to secure accolades and positive legal news media representation.
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October 22, 2024
Director Imprisoned For Concealing £220K Tax Debt
The former director of a wholesale company has been jailed for 10 months after failing to deliver accounting records when his business went into liquidation owing more than £220,000 ($290,000), the Insolvency Service announced Tuesday.
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October 22, 2024
Germany's Sept. Tax Revenue Rises 6.9% Year-On-Year
Germany's total tax revenue for the month of September reached €86.2 billion ($93.2 billion) after a rise in tax receipts over the summer, an increase of 6.9% year-on-year, the German Ministry of Finance said Tuesday.
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October 22, 2024
MVP: Jones Day's Charles 'Chuck' Hodges
Chuck Hodges, a tax partner with Jones Day, led a gravel company to victory in May at the U.S. Tax Court in a case regarding an $11.1 million sale of a freeway pit, helping him earn a spot as one of the 2024 Law360 Tax MVPs.
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October 22, 2024
Budget Fears Spark Surge Of Savers Raiding Pensions
A third of financial advisers have seen an uptick in customers tapping into their pensions, an investment platform company said, amid speculation the government could reduce the amount that Britons can withdraw without being taxed.
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October 21, 2024
BDO Appoints Former HMRC Official, 3 Others To UK Offices
An HM Revenue & Customs official is among four tax professionals BDO LLP has appointed to its offices in the U.K., the firm announced.
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October 21, 2024
Foreign Currency Regs Need Flexibility, Biz Group Says
The U.S. Treasury Department should allow taxpayers with foreign personal holding companies to get automatic consent to revoke elections on the treatment of foreign currency gains or losses under proposed regulations to align such elections with rules on so-called mark-to-market accounting, the National Foreign Trade Council said.
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October 21, 2024
UK Director's Use Of Tax Planning Data Subject For Retrial
Whether a director of a U.K. company is liable for a breach of confidence over the misuse of information in marketing a complex tax structure is an issue to be retried, a London court ruled.
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October 21, 2024
MVP: Paul Weiss' Brian Krause
Brian Krause of Paul Weiss Rifkind Wharton & Garrison LLP's tax practice designed a novel tax approach for the merger of World Wrestling Entertainment and Ultimate Fighting Championship, raced to create a tax-free deal in the final days of a Texas "wildcatter" hoping to sell his oil company, and advised Chevron in its $60 billion acquisition of Hess Corp., earning him a spot as one of the 2024 Law360 Tax MVPs.
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October 21, 2024
Estonian Tax System Remains Most Competitive, Study Says
Estonia's tax system was ranked by a conservative think tank as the most competitive out of the Organization for Economic Cooperation and Development's 38 full members for the 11th year in a row, while the U.S. improved to 18th, according to a report Monday.
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October 21, 2024
14 Arrested In Poland For $10M VAT Fraud Involving Trucks
Polish authorities arrested 14 suspects in connection to a value-added tax fraud scheme involving the import of trucks from other European Union member countries that caused losses worth an estimated 40 million Polish zloty ($10 million), the country's revenue agency said Monday.
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October 21, 2024
Canada Offers Relief From Surtaxes On Chinese Imports
Canadian businesses can now apply under certain conditions for relief from surtaxes the country enacted on Chinese-made electric vehicles and some Chinese steel and aluminum products, the country's Department of Finance said.
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October 21, 2024
New ABA Tax Chair-Elect Aims To Expand Leadership Paths
The new chair-elect of the American Bar Association Section of Taxation told Law360 that she wants to broaden the pathways to leadership for members, including those early in their careers, as part of the section's diversity, equity and inclusion initiatives. Here, Megan Brackney shares more about her background and goals for the section.
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October 18, 2024
Law360 MVP Awards Go To Top Attys From 74 Firms
The attorneys chosen as Law360's 2024 MVPs have distinguished themselves from their peers by securing hard-earned successes in high-stakes litigation, complex global matters and record-breaking deals.
Expert Analysis
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Unpacking FinCEN's Proposed Real Estate Transaction Rule
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.
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Think Like A Lawyer: Forget Everything You Know About IRAC
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.
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How New EU Tax And Transfer Pricing Rules May Affect M&A
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.
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How Firms Can Ensure Associate Gender Parity Lasts
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.
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7 Common Myths About Lateral Partner Moves
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.
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6 Pointers For Attys To Build Trust, Credibility On Social Media
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.
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US-Chile Tax Treaty May Encourage Cross-Border Investment
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.
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A Post-Mortem Analysis Of Stroock's Demise
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.
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SG's Office Is Case Study To Help Close Legal Gender Gap
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.
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Reimagining Law Firm Culture To Break The Cycle Of Burnout
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.
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Cayman Islands Off AML Risk Lists, Signaling Robust Controls
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.
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The Legal Industry Needs A Cybersecurity Paradigm Shift
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.
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As Promised, IRS Is Coming For Crypto Tax Evaders
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.