International
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November 26, 2024
Australia Will Enact Pillar 2 Minimum Corporate Tax
Australia will institute the Organization for Economic Cooperation and Development's global corporate minimum tax under legislation enacted Tuesday by Parliament.
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November 26, 2024
Many OECD Gov'ts Need More Tax Transparency, Report Says
Peer reviews found nearly half of OECD countries need to improve their legal frameworks for the automatic exchange of financial account information, a decade-old tax transparency system crafted by the organization, while many developing countries received passing grades, according to a report released Tuesday.
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November 26, 2024
OECD Suggests Indonesia Broaden Its Tax Base
Indonesia should broaden its tax base to account for long-term spending pressures like an aging population, the Organization for Economic Cooperation and Development said Tuesday, while also recommending the country pick up the pace on implementing a carbon tax.
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November 26, 2024
UK Gov't Urged To Hold Off On Changes To Inheritance Tax
The British Labour government should hold off on inheritance tax changes for farmers, scheduled to take effect in April, that would make gifts to their heirs taxable if they occur within seven years of the giver's death, a U.K. economics think tank said.
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November 26, 2024
Two Arrested In €19M VAT Fraud Involving VoIP
Authorities arrested two people Tuesday alleging their participation in a €19 million ($19.9 million) value-added tax fraud scheme involving services that let users make phone calls via the internet, the European Public Prosecutor's Office said.
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November 26, 2024
Gov't, US-Saudi Former Pilot Close $1.2M FBAR Suit
A U.S.-Saudi citizen who's been a pilot and luxury airplane consultant settled his $1.2 million dispute with the U.S. government over bank accounts in Switzerland that the IRS said he failed to report.
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November 26, 2024
IRS Confirms Commerce Payments In Chips Tax Credit
Semiconductor development projects that received funding awards from the U.S. Commerce Department's CHIPS incentives program are considered investments that can also take advantage of the advanced manufacturing tax credit, the Internal Revenue Service confirmed Tuesday in guidance.
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November 26, 2024
UK Gov't Urged To Rethink Inheritance Tax Plan For Pensions
The government should consider alternatives to its plan to bring pension assets within the scope of inheritance tax, an online investment company has said, warning that the current proposals could create "financial gridlock."
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November 25, 2024
Ex-DOJ Attorney Joins Moore Tax Law Group In Chicago
The Moore Tax Law Group has brought on a former trial attorney for the U.S. Department of Justice, Tax Division, the firm announced.
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November 25, 2024
UK Releases Deadlines For Top-Up Tax Payments
The U.K. government issued new guidance detailing how multinational corporations should pay domestic and multinational top-up taxes under the Organization for Economic Cooperation and Development's Pillar Two 15% global minimum tax, providing payment deadlines and methods for compliance.
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November 25, 2024
Aussie Gov't Proposes Green Energy Production Tax Credits
Australia's government has unveiled a sweeping new tax incentive program to accelerate investment in renewable hydrogen and critical minerals in an attempt to meet its commitment to a net-zero energy transformation.
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November 25, 2024
Payments To Exxon Unit Taxable, Australian Panel Says
Exxon Mobil unit Esso is liable for tax on monthly payments it received for processing its Australian business partners' petroleum and on an AU$23.4 million ($15.5 million) lump sum payment, a panel at the Federal Court of Australia said, overturning an earlier judgment at the same court.
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November 25, 2024
Feds Violated Atty-Client Rules, Tax Evasion Defendant Says
A Brazilian-American businessman accused of using Swiss bank accounts to hide $20 million from the Internal Revenue Service asked a Florida federal court to dismiss all the charges against him, saying federal prosecutors improperly gained access to information protected by attorney-client privilege.
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November 25, 2024
IRS Corrects Advanced Manufacturing Production Credit Regs
The Internal Revenue Service issued a correction notice Monday concerning final rules for the advanced manufacturing production credit.
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November 25, 2024
Tax Hikes Will Make It Harder To Hire, UK Industry Chief Says
Businesses will hire fewer workers as a result of raising employers' National Insurance contributions, a payroll levy, that was introduced in the autumn budget, the chief of one of Britain's most influential industry groups said Monday.
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November 22, 2024
Trump Taps Hedge Fund Billionaire Bessent To Head Treasury
President-elect Donald Trump on Friday announced that he's selected Scott Bessent, a billionaire hedge fund manager and the founder of Key Square Group, to serve as secretary of the Treasury in his upcoming administration.
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November 22, 2024
IRS Extends Domestic Content Relief For Energy Credits
Nonprofits, tribal governments, public utilities and other tax-exempt groups eligible for a direct cash payment of their clean energy tax credits can get relief from meeting the domestic content requirements tied to those incentives for 2025 and 2026 under IRS guidance released Friday.
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November 22, 2024
Canada Proposing 2-Month GST Holiday For Groceries, Gifts
Canada's government is sending a proposal to its Parliament that would implement a two-month goods-and-services tax holiday starting in mid-December on goods ranging from certain groceries to Christmas trees.
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November 22, 2024
Isle Of Man Parliament Passes OECD's Global Minimum Tax
The Isle of Man's Parliament approved a bill implementing two portions of the Organization for Economic Cooperation and Development's 15% global minimum tax on large multinational entities making at least €750 million ($781 million) annually, starting in 2025.
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November 22, 2024
Halliburton Omitted Grounds From $35M Refund Suit, US Says
A Texas federal court must dismiss parts of Halliburton's $35 million tax refund lawsuit because the company failed to raise two grounds of relief in its administrative claim for a refund, the U.S. argued.
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November 22, 2024
Taxation With Representation: Stradley Ronon, Davis Polk
In this week's Taxation With Representation, Amcor PLC buys Berry Global Group Inc., AeroVironment buys BlueHalo, Robinhood Markets Inc. acquires TradePMR, and Comcast Corp. spins off a suite of NBCUniversal cable television networks.
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November 22, 2024
2 Convicted In €3.7M EU VAT Fraud Scheme
A German court convicted two people for their roles in a value-added tax fraud scheme involving small electronic goods that caused an estimated €3.7 million ($3.86 million) in lost tax revenue, the European Public Prosecutor's Office said.
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November 22, 2024
Spain Raises Bank Windfall Levy, Enacts Minimum Tax
The Spanish government is set to increase its windfall tax on banks with more than €5 billion ($5.2 billion) in income as well as implement a minimum corporate tax on multinational companies following a vote by lawmakers.
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November 21, 2024
Australia Floats Paths For Adopting Crypto Disclosure Rules
The Australian government floated two options Thursday for implementing a global crypto-asset reporting framework: adopt a standardized model or take a "bespoke approach" that would offer more flexibility but may also increase compliance costs.
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November 21, 2024
Breach Of VAT Rules Can Block €385K Refund, ECJ Rules
Bulgarian tax authorities can deny a value-added tax refund of approximately €385,000 ($403,000) to a domestic company that did not have the tax itemized on invoices, the European Court of Justice ruled Thursday.
Aussie Court Affirms R&D Credit Denial For Basketball Shoe
The Australian producer of a basketball shoe cannot count its activities as research and development for tax purposes because of a lack of details on the shoe's development, the Federal Court of Australia ruled Monday.
IRS Ignores Text In $248M Fight, Liberty Global Tells 10th Circ.
The Internal Revenue Service is incorrectly applying the U.S. tax code in denying Liberty Global's claim for $248 million in foreign tax credits tied to its sale of a Japanese affiliate, the telecommunications company told the Tenth Circuit.
EU Official Says GILTI Changes Could Nullify Pillar 2 Backstop
The U.S. has an opportunity to shield multinationals from the Pillar Two 15% global minimum tax backstop rule in other jurisdictions by revising its tax on global intangible low-taxed income next year, a European Union tax official said Thursday.
Aussie Court Affirms R&D Credit Denial For Basketball Shoe
The Australian producer of a basketball shoe cannot count its activities as research and development for tax purposes because of a lack of details on the shoe's development, the Federal Court of Australia ruled Monday.
IRS Ignores Text In $248M Fight, Liberty Global Tells 10th Circ.
The Internal Revenue Service is incorrectly applying the U.S. tax code in denying Liberty Global's claim for $248 million in foreign tax credits tied to its sale of a Japanese affiliate, the telecommunications company told the Tenth Circuit.
EU Official Says GILTI Changes Could Nullify Pillar 2 Backstop
The U.S. has an opportunity to shield multinationals from the Pillar Two 15% global minimum tax backstop rule in other jurisdictions by revising its tax on global intangible low-taxed income next year, a European Union tax official said Thursday.
Featured Stories
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Countries Eye Certain Tax Credits To Get Leg Up Under Pillar 2
The international minimum tax agreement known as Pillar Two is changing how countries compete for corporate investment, in part by prompting some governments to retool their tax credit systems in ways that could edge out jurisdictions with fewer resources.
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The Tax Angle: TCJA Debate, S Corp. Compliance
From a look at congressional lawmakers ramping up their debate over the expiration of the GOP's 2017 tax overhaul law to the IRS' plans to provide more oversight for pass-through businesses and S corporations, here's a peek into a reporter's notebook on a few of the week's developing tax stories.
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Trump, GOP Victories May Imperil OECD Global Tax Plan
President-elect Donald Trump's and Republicans' victories in the U.S. elections this month call into question whether the OECD's two-pillar global tax plan can be effectively implemented and whether the plan's minimum tax backstop rule can be applied amid threats of retaliatory tax measures by the U.S.
Expert Analysis
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3 Ways To Train Junior Lawyers In 30 Minutes Or Less
Today’s junior lawyers are experiencing a skills gap due to pandemic-era disruptions, but firms can help bring them up to speed by offering high-impact skill building content in bite-sized, interactive training sessions, say Stacey Schwartz at Katten, Diane Costigan at Winston & Strawn and Lauren Tierney at Freshfields.
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The Bar Needs More Clarity On The Discovery Objection Rule
Almost 10 years after Federal Rule of Civil Procedure 34 was amended, attorneys still seem confused about what they should include in objections to discovery requests, and until the rules committee provides additional clarity, practitioners must beware the steep costs of noncompliance, says Tristan Ellis at Shanies Law Office.
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So You Want To Move Your Law Practice To Canada, Eh?
Google searches for how to move to Canada have surged in the wake of the U.S. presidential election, and if you’re an attorney considering a move to the Great White North, you’ll need to understand how the practice of law differs across the border, says David Postel at Henein Hutchison.
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Promoting Diversity In The Selection Of ADR Neutrals
Excerpt from Practical Guidance
Choosing neutrals from diverse backgrounds is an important step in promoting inclusion in the legal profession, and it can enhance the legitimacy and public perception of alternative dispute resolution proceedings, say attorneys at Lowenstein Sandler.
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Striking A Balance Between AI Use And Attorney Well-Being
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As the legal industry increasingly adopts generative artificial intelligence tools to boost efficiency, leaders must note the hidden costs of increased productivity, and work to protect attorneys’ well-being while unlocking AI’s full potential, says Ed Sohn at Factor.
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How Judiciary Can Minimize AI Risks In Secondary Sources
Because courts’ standing orders on generative artificial intelligence and other safeguards do not address the risk of hallucinations in secondary source materials, the judiciary should consider enlisting legal publishers and database hosts to protect against AI-generated inaccuracies, say attorneys at Lankler Siffert & Wohl.
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How Attorneys Can Break Free From Career Enmeshment
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Ambitious attorneys can sometimes experience career enmeshment — when your sense of self-worth becomes unhealthily tangled up in your legal vocation — but taking the time to discover and realign with your core personal values can help you recover your identity, says Janna Koretz at Azimuth Psychological.
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Lawyers With Disabilities Are Seeking Equity, Not Pity
Attorneys living with disabilities face extra challenges — including the need for special accommodations, the fear of stigmatization and the risk of being tokenized — but if given equitable opportunities, they can still rise to the top of their field, says Kate Reder Sheikh, a former attorney and legal recruiter at Major Lindsey & Africa.
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Judicial Committee Best Venue For Litigation Funding Rules
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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
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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.