International
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May 23, 2024
Yellen Opposes Global Redistribution Of Billionaires' Wealth
U.S. Treasury Secretary Janet Yellen repeated Thursday that she opposes a global minimum tax on billionaires and added that she does not support basing a redistribution of the revenue from such a tax on damage from climate change and related financing needs.
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May 23, 2024
G7 Should Agree On Frozen Russian Assets, Yellen Says
U.S. Treasury Secretary Janet Yellen said Thursday that the Group of Seven countries should agree now on a concept of how the capital of frozen and immobilized Russian state assets should be used to support Ukraine's war against Russia.
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May 23, 2024
EU Could Add Sectors To Border Tax, Commissioner Says
The European Union should consider expanding its carbon border tax beyond the initial sectors covered, an EU commissioner has said.
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May 23, 2024
Akerman Brings On Kilpatrick Tax Ace In LA
Akerman LLP is boosting its tax team, bringing in a Kilpatrick Townsend & Stockton LLP corporate tax and energy tax credit expert as a partner in its Los Angeles office.
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May 22, 2024
Justices' CFPB Alliance May Save SEC Courts, Not Chevron
A four-justice concurrence to the U.S. Supreme Court's decision upholding the Consumer Financial Protection Bureau's unique funding scheme last week carries implications for other cases pending before the court that challenge the so-called administrative state, or the permanent cadre of regulatory agencies and career government enforcers who hold sway over vast swaths of American economic life.
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May 22, 2024
German Legislature Moves To Update Certain Tax Treaties
The lower house of Germany's legislature has approved a bill to update multiple bilateral tax treaties as part of the country's implementation of the Organization for Economic Cooperation and Development's project against base erosion and profit shifting.
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May 22, 2024
Doctor Must Stay In Jail In Tax Penalty Fight, Gov't Says
A doctor incarcerated for civil contempt for not paying $1.1 million in penalties for failing to report his foreign accounts should remain in jail until he has done more to comply, the U.S. government told a Michigan federal court Wednesday.
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May 22, 2024
Belgium Provides Pillar 2 Reporting Rules
Belgium's finance ministry has issued guidance on what large multinational entities and domestic groups will need to do to comply with the country's coming registration requirement as part of its implementation of the Organization for Economic Cooperation and Development's global corporate minimum tax.
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May 22, 2024
Guernsey Joins Crown Dependencies Moving Toward Pillar 2
Guernsey will soon take steps to implement the OECD's 15% global minimum tax on large multinational corporations making €750 million ($813 million) annually, in line with fellow U.K. crown dependencies the Isle of Man and Jersey, the island's Finance Ministry said.
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May 22, 2024
Property Transfer For Tax Break Not Dishonest, UK Court Says
Two liquidated London real estate companies failed to convince the United Kingdom Court of Appeal that their former director behaved dishonestly by transferring their holdings to Jersey trusts for less than market value to obtain a tax advantage, according to a judgment released Wednesday.
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May 22, 2024
IRS Again Delays Reporting Rules for Certain BEAT Payments
The Internal Revenue Service is deferring until 2027 the applicability date of requirements for reporting certain intercompany payments that are exempt from the base erosion and anti-abuse tax, the agency announced Wednesday.
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May 22, 2024
IRS Again Delaying Dividend Anti-Abuse Regs
The Internal Revenue Service is again extending the transition period for rules that govern certain financial transactions that could avoid withholding on dividend payments to foreign taxpayers, it announced Wednesday.
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May 22, 2024
UK Gov't Calls Elections For July 4 Despite Poor Polls
Prime Minister Rishi Sunak on Wednesday called an early general election to be held on July 4, advancing the electoral timetable even though his Conservative Party lags decisively behind the opposition Labour Party.
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May 22, 2024
Swiss Gov't Adopts Proposals For Tougher AML Laws
Switzerland on Wednesday approved a new anti-money laundering framework that will introduce a register in which companies and other legal entities in the country will have to disclose information on their beneficial owners in a major shift in its anti-money laundering rules.
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May 22, 2024
EU's Carbon Border Tax Pushes Others To Follow, Experts Say
The European Union's carbon border tax is pushing many countries outside the bloc to introduce similar systems, government and academic experts said Wednesday.
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May 22, 2024
UK Dependency To Implement Pillar 2 Starting In 2025
The island of Jersey, a U.K. crown dependency, said it would implement the international minimum tax for large corporations known as Pillar Two, with the law taking effect next year.
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May 21, 2024
Nixing Green Energy Tax Perks Would Be Tough For Trump
Former President Donald Trump has vowed to scrap Democrats' signature 2022 climate law should he get reelected in November, but following through on that campaign promise could prove difficult amid bipartisan support for many of the law's clean energy tax incentives and a potentially divided Congress.
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May 21, 2024
Wyden Expands Pharma Tax Investigation With Pfizer Inquiry
Senate Finance Committee Chairman Ron Wyden asked Pfizer to provide details on its tax practices to explain how the drug company has consistently paid tax rates that are significantly lower than the corporate tax rate in a letter released by the committee Tuesday.
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May 21, 2024
CohnReznick Adds PwC Partner To International Tax Practice
CohnReznick has a new principal in its international tax practice who previously served as a partner at PwC, the firm announced.
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May 21, 2024
22 States Tell 11th Circ. Corp. Transparency Act Goes Too Far
The federal Corporate Transparency Act unconstitutionally displaces state authority and its enforcement would economically harm states and their residents, attorneys general from 22 states told the Eleventh Circuit, urging it to uphold a ruling that struck down the law.
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May 21, 2024
Yellen Says US Can't Support Global Tax On Billionaires
Treasury Secretary Janet Yellen said the U.S. can't support Brazil's proposal for the Group of 20 nations to endorse pursuing a multilateral agreement to tax billionaires' wealth at a minimum rate.
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May 21, 2024
Italy Needs To Adjust Tax Credits To Limit Debt, IMF Says
While generous Italian tax regimes such as credits for home improvements have helped the country's economy rebound quickly from the pandemic, they also pose a risk to the country's debt burden and need to be adjusted, the International Monetary Fund said.
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May 21, 2024
Strategic Hiring Was The New Normal For BigLaw In 2023
The 400 largest law firms by headcount in the U.S. grew more slowly in 2023 than in the previous two years, while Kirkland & Ellis LLP surpassed the 3,000-attorney threshold, according to the latest Law360 ranking.
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May 21, 2024
The Law360 400: Tracking The Largest US Law Firms
The legal market expanded more tentatively in 2023 than in previous years amid a slowdown in demand for legal services, especially in transactions, an area that has been sluggish but is expected to quicken in the near future.
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May 21, 2024
Portuguese Cos. Appeal EU Court Ruling On Tax Breaks
Three Portuguese companies have appealed a European Union court's judgment backing a European Commission decision that demanded repayment of tax breaks considered to have been illegal, documents published Tuesday showed.
Expert Analysis
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Post-Election Tax Policy Scenario 1: A Republican Sweep
Attorneys at Brownstein Hyatt analyze tax policies implemented by the Trump administration, such as the Tax Cuts and Jobs Act, and consider what will be on the agenda if Republicans gain full control of both the legislative and executive branches in the election.
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Defensive Strategies For High-Net-Worth Individual Tax Audits
When representing high-net-worth individuals in a tax audit, defensive strategies that cooperate with the examiner and respond to government requests should reflect the overarching goal of preserving client objections, privileges, limitations periods and any other rights in case there is future litigation, says Patrick McCann at Chamberlain Hrdlicka.
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Canadian Tax Ruling Signals Cross-Border Structure Security
After the Tax Court of Canada's recent ruling in AgraCity v. The Queen that the company's arm's-length tax arrangements with a foreign subsidiary were legitimate, and a similar result in a different matter, Canadian taxpayers can have confidence that their cross-border related party transaction structures will be upheld, says Matt Billings at Duff & Phelps.
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Preparing The Next Generation Of Female Trial Lawyers
To build the ranks of female trial attorneys, law firms must integrate them into every aspect of a case — from witness preparation to courtroom arguments — instead of relegating them to small roles, says Kalpana Srinivasan, co-managing partner at Susman Godfrey.
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Mentorship Is Key To Fixing Drop-Off Of Women In Law
It falls to senior male attorneys to recognize the crisis female attorneys face as the pandemic amplifies an already unequal system and to offer their knowledge, experience and counsel to build a better future for women in law, says James Meadows at Culhane Meadows.
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5 Ways Firms Can Avoid Female Atty Exodus During Pandemic
The pandemic's disproportionate impact on women presents law firms with a unique opportunity to devise innovative policies that will address the increasing home life demands female lawyers face and help retain them long after COVID-19 is over, say Roberta Liebenberg at Fine Kaplan and Stephanie Scharf at Scharf Banks.
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IRS Real Estate Push Should Wake Up Foreign Investors
Two recently announced Internal Revenue Service audit campaigns targeting nonresident alien investment in U.S. real estate should prompt foreign investors to prepare for greater scrutiny as the agency works to improve tax compliance around such transactions, say attorneys at Holland & Knight.
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CFTC Climate Change Report Highlights Costs Of Inaction
The Commodity Futures Trading Commission's recent report on climate change and financial markets makes it clear that while government regulation of carbon dioxide pollution may have negative consequences, letting greenhouse gas emissions go unaddressed could harm investors, asset managers and financial institutions, says Nicholas Fox at Goldberg Segalla.
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Dems' Int'l Tax Policy Comes With Unintended Consequences
Former Vice President Joe Biden and Sen. Kamala Harris’ "Made in America" tax policy overstates the importance of revenue raising, which may encourage foreign ownership of global activity and disadvantage U.S.-based companies, says George Callas at Steptoe & Johnson.
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How Cos. Can Respond To Growing Crypto Tax Enforcement
As the U.S. Department of Justice and the Internal Revenue Service remain laser-focused on abusive cryptocurrency schemes, companies operating in this high-risk industry should review their compliance measures in areas such as data analysis, employee oversight and industry benchmarking, say attorneys at Norton Rose.
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Trump's Tax Tactics May Be Criminal
Apologists who defend President Donald Trump as having shrewdly exploited legal loopholes by deducting dubious consulting fees from his taxes are ignoring major badges of fraud that would have led the Internal Revenue Service to investigate any other taxpayer, says Daren Firestone at Levy Firestone.
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Why Cum-Ex Tax Fraud Probes Are On The Rise
Neil Williams at Rahman Ravelli outlines why European regulatory investigations into cum-ex — a 1990s-era dividend arbitrage trading practice involving tax rebate claims worth tens of billions of euros — are gaining momentum years after the activities that sparked them, and who should be concerned.
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Managing New IRS Global High-Wealth Audits
Global high-wealth individuals on the receiving end of an audit letter under the Internal Revenue Service Large Business and International Division's new program should prepare for a thorough examination process that includes their entire network of persons and affiliated entities, say attorneys at MoFo.