International

  • October 24, 2024

    Politics Blocking Amount B Consensus, OECD Tells G20

    Continued delays of the Organization for Economic Cooperation and Development's transfer pricing plan for certain baseline marketing and distribution activities known as Amount B of Pillar One are due to "primarily political" issues as opposed to technical problems, the organization told the Group of 20 on Thursday.

  • October 24, 2024

    Dutch Gov't Seeks Feedback On Crypto Reporting Rules

    The Netherlands is looking for input on a proposal that would implement European Union rules requiring crypto-asset service providers to collect, check and share their users' data with the country's tax authority, the Dutch Ministry of Finance said Thursday.

  • October 24, 2024

    Aussie Board Seeks Input On Tax Pro Code Update Guidance

    The Australian Tax Practitioners Board is looking for feedback on guidance related to six amendments to the country's tax professional code of conduct that were made in response to the PwC document leak scandal, the board said Thursday.

  • October 24, 2024

    119K Residents Didn't Report Foreign Accounts, HMRC Says

    Around 119,000 U.K. residents failed to declare their foreign accounts in fiscal year 2018-19 with HM Revenue & Customs, the British tax authority said Thursday.

  • October 24, 2024

    Sweden Moves To Suspend Tax Treaty With Russia

    Sweden is looking to suspend its double-tax treaty with Russia in response to Russia's cessation of parts of their treaty last year, Sweden's Ministry of Finance said Thursday.

  • October 24, 2024

    MVP: Sidley Austin's Rachel D. Kleinberg

    Rachel D. Kleinberg, a co-leader of the global tax practice at Sidley Austin LLP, headed up a tax team to represent investors in a consortium that led to the $6.05 billion sale of the NFL's Washington Commanders, earning her a spot as one of the 2024 Law360 Tax MVPs.

  • October 24, 2024

    Charles Russell Brings On Tax Specialist From Sheridans

    Charles Russell Speechlys LLP hired a partner from Sheridans as part of expanding its London tax practice to support its strategy focused on private capital, the firm said.

  • October 24, 2024

    Mining Eligible In Final Regs For Energy Manufacturing Credit

    The U.S. Treasury Department's final rules released Thursday on a valuable tax credit for manufacturing key components and materials used in clean energy technologies allow producers to take into account the costs to mine and extract critical minerals.

  • October 23, 2024

    IRS To Split Pass-Through, Energy Credit Work Into 2 Units

    The IRS is planning to split up its Pass-Throughs and Special Industries office into two separate divisions, including one that will focus in part on energy credits enacted under the 2022 landmark climate law, an agency official said Wednesday.

  • October 23, 2024

    COST Urges Justices To Hear IBM, Disney Appeals Of NY Tax

    New York's method of taxing IBM and The Walt Disney Co.'s royalties received from foreign affiliates resulted in an unconstitutional discrimination against interstate commerce that warrants U.S. Supreme Court scrutiny, the Council on State Taxation told the justices Wednesday.

  • October 23, 2024

    Microsemi's Fines Mostly Adhered To Rules, Tax Court Says

    The Internal Revenue Service obtained the proper written approval of penalties on most of the tax code violations it brought against semiconductor manufacturer Microsemi but left room for doubt on two penalties, the U.S. Tax Court said.

  • October 23, 2024

    ECJ Won't Call Off Clawback Of Portugal's Tax Breaks

    The European Court of Justice declined to overturn a European Commission decision that Portugal must claw back tax breaks provided in a free trade zone to companies with no local economic activity, as those breaks violated the bloc's state aid rules, according to a judgment issued Wednesday.

  • October 23, 2024

    Australian Greens Support Digital Tax On Tech Cos.

    The Australian Greens party recommended that the country's government pursue a digital services tax similar to those in France and Canada as a way to make companies such as Meta pay their "fair share."

  • October 23, 2024

    EU Tax Nominee Vows Corp. Tax Simplification, Pillar 1 Work

    The nominee to serve as the European Union's next tax commissioner pledged to simplify corporate rules and affirmed his support for the reallocation of taxing rights known as Pillar One in remarks to the European Parliament.

  • October 23, 2024

    ABA Tax Section Pushes IRS To Narrow Pillar 2 Regulations

    Proposed regulations outlining when foreign taxes under the Pillar Two international minimum tax agreement trigger U.S. rules against benefiting twice from the same economic loss should be narrowed to limit their applicability, the American Bar Association Tax Section told the IRS.

  • October 23, 2024

    IRS Grants Tax-Exempt Entities Relief From Corp. AMT Filing

    Tax-exempt entities are not obligated to file the corporate alternative minimum tax form for the 2023 tax year with the Internal Revenue Service, but they should still maintain the document for recordkeeping purposes, the agency announced Wednesday. 

  • October 23, 2024

    EU OKs Swedish Biogas Tax Breaks After Review

    Two Swedish tax exemptions — one for nonfood-based biogas, the other for biopropane used for heating — are in line with European Union state aid rules, the European Commission said Wednesday following a probe into the measures.

  • October 23, 2024

    Judge Threatens To Toss Gov't's $4.9M Son-Of-Boss Claim

    A federal judge warned government attorneys Wednesday that she would dismiss their case against an estate for $4.9 million in taxes if they didn't explain why they weren't actively pursuing their accusations that a Michigan couple schemed to artificially cancel out capital gains

  • October 23, 2024

    Jersey Adopts Global Minimum Tax

    Jersey has adopted the Organization for Economic Cooperation and Development's 15% minimum tax on multinational entities making over €750 million ($808 million) annually, which will take effect in the jurisdiction in 2025.

  • October 23, 2024

    MVP: Sullivan & Cromwell's Eric Wang

    Sullivan & Cromwell's S. Eric Wang advised clients on the tax law implications of major deals over the past year, including a transaction that created the largest gas utility company in North America, earning him a spot as one of the 2024 Law360 2024 Tax MVPs.

  • 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.

  • 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.

  • 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.

  • 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.

  • 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.

Expert Analysis

  • 5 Tips To Succeed In A Master Of Laws Program And Beyond

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    As lawyers and recent law school graduates begin their Master of Laws coursework across the country, they should keep a few pointers in mind to get the most out of their programs and kick-start successful careers in their practice areas, says Kelley Miller at Reed Smith.

  • How Law Firms Can Avoid 'Collaboration Drag'

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    Law firm decision making can be stifled by “collaboration drag” — characterized by too many pointless meetings, too much peer feedback and too little dissent — but a few strategies can help stakeholders improve decision-making processes and build consensus, says Steve Groom at Miles Mediation.

  • Litigation Funding Disclosure Key To Open, Impartial Process

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    Blanket investor and funding agreement disclosures should be required in all civil cases where the investor has a financial interest in the outcome in order to address issues ranging from potential conflicts of interest to national security concerns, says Bob Goodlatte, former U.S. House Representative for Virginia.

  • What NFL Draft Picks Have In Common With Lateral Law Hires

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    Nearly half of law firm lateral hires leave within a few years — a failure rate that is strikingly similar to the performance of NFL quarterbacks drafted in the first round — in part because evaluators focus too heavily on quantifiable metrics and not enough on a prospect's character traits, says Howard Rosenberg at Baretz+Brunelle.

  • Replacing The Stigma Of Menopause With Law Firm Support

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    A large proportion of the workforce is forced to pull the brakes on their career aspirations because of the taboo surrounding menopause and a lack of consistent support, but law firms can initiate the cultural shift needed by formulating thoughtful workplace policies, says Barbara Hamilton-Bruce at Simmons & Simmons.

  • Planning Law Firm Content Calendars: What, When, Where

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    During the slower month of August, law firms should begin working on their 2025 content calendars, planning out a content creation and distribution framework that aligns with the firm’s objectives and maintains audience engagement throughout the year, says Jessica Kaplan at Legally Penned.

  • Law Firms Should Move From Reactive To Proactive Marketing

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    Most law firm marketing and business development teams operate in silos, leading to an ad hoc, reactive approach, but shifting to a culture of proactive planning — beginning with comprehensive campaigns — can help firms effectively execute their broader business strategy, says Paul Manuele at PR Manuele Consulting.

  • The Big Issues A BigLaw Associates' Union Could Address

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    A BigLaw associates’ union could address a number of issues that have the potential to meaningfully improve working conditions, diversity and attorney well-being — from restructured billable hour requirements to origination credit allocation, return-to-office mandates and more, says Tara Rhoades at The Sanity Plea.

  • It's Time For A BigLaw Associates' Union

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    As BigLaw faces a steady stream of criticism about its employment policies and practices, an associates union could effect real change — and it could start with law students organizing around opposition to recent recruiting trends, says Tara Rhoades at The Sanity Plea.

  • How Justices Upended The Administrative Procedure Act

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    In its recent Loper Bright, Corner Post and Jarkesy decisions, the U.S. Supreme Court fundamentally changed the Administrative Procedure Act in ways that undermine Congress and the executive branch, shift power to the judiciary, curtail public and business input, and create great uncertainty, say Alene Taber and Beth Hummer at Hanson Bridgett.

  • Tips For Tax Equity-Tax Credit Transfers That Pass IRS Muster

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    Although the Internal Revenue Service has increased its scrutiny of complex partnership structures, which must demonstrate their economic substance and business purpose, recent cases and IRS guidance together provide a reliable road map for creating legitimate tax equity structures, say Ian Boccaccio and Michael Messina at Ryan Tax.

  • Mirror, Mirror On The Wall, Is My Counterclaim Bound To Fall?

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    A Pennsylvania federal court’s recent dismissal of the defendants’ counterclaims in Morgan v. Noss should remind attorneys to avoid the temptation to repackage a claim’s facts and law into a mirror-image counterclaim, as this approach will often result in a waste of time and resources, says Matthew Selmasska at Kaufman Dolowich.

  • 3 Leadership Practices For A More Supportive Firm Culture

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    Traditional leadership styles frequently amplify the inherent pressures of legal work, but a few simple, time-neutral strategies can strengthen the skills and confidence of employees and foster a more collaborative culture, while supporting individual growth and contribution to organizational goals, says Benjamin Grimes at BKG Leadership.

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