International
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August 06, 2024
Austria Records 'Problematic' Rise In Fake Companies
Fake companies are on the rise in Austria, the country's Finance Ministry said Tuesday, adding that it hoped that a newly agreed-to law against tax evasion and fraud could reverse the trend.
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August 05, 2024
FedEx Asserts Chevron Ruling Supports $84.6M Refund
The U.S. Supreme Court's recent rejection of the Chevron doctrine entitles FedEx to an $84.6 million tax refund by taking credits for foreign taxes it paid on offset earnings when repatriating overseas income, the package delivery giant told a Tennessee federal court.
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August 05, 2024
Pension Plan Testimony Barred In $2B Danish Tax Fraud Case
U.S. pension plans have proposed irrelevant expert testimony in response to allegations of their participation in a $2.1 billion Danish tax fraud scheme, a New York federal judge ruled in excluding the testimony but leaving room to try again.
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August 05, 2024
Latest Draft Widens Scope Of UN Tax Convention
Diplomats would gain flexibility on the scope, commitments and source material of a United Nations convention on international tax cooperation under a revised guidance for negotiators released ahead of a debate Monday as preliminary talks inch closer to finishing.
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August 05, 2024
Turkey Enacts Global Corporate Minimum Tax
Turkey enacted the Organization for Economic Cooperation and Development's 15% corporate minimum tax on large multinational entities making more than €750 million ($821 million) annually.
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August 05, 2024
EU Court To Hear Czech Value-Added Tax Case
The Court of Justice of the European Union will consider a case from the Czech Republic concerning whether the bloc's value-added tax system and proportionality principle precludes a Czech law regarding the transfers of VAT payment liabilities, the EU said Monday.
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August 05, 2024
Free Market Group Challenges EU Pillar 2 Directive In Court
A free market trade group is taking aim in court at the European Union's implementation of the OECD's Pillar Two anti-tax base erosion and profit shifting measures, which it claims are unfairly impacting the U.S. and subverting Congress' right to tax U.S. companies.
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August 05, 2024
Peru To Subject Foreign Platforms To Sales Tax
Foreign digital service providers doing business in Peru will be subject to the country's sales tax starting in October, in line with Organization for Economic Cooperation and Development standards, according to a legislative decree.
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August 05, 2024
Russia Increasing Corporate Tax Rates In 2025
Corporations in Russia will be assessed a 25% income tax rate starting in 2025, an increase from the current 20%, the country's tax agency said Monday.
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August 02, 2024
Ex-Loeb Tax Atty Latest Addition To Kilpatrick's NY Team
A former Loeb & Loeb LLP attorney is bringing his experience in U.S. federal tax matters and real estate transactions to Kilpatrick Townsend & Stockton LLP, the firm announced Thursday.
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August 02, 2024
Aussie Panel Opposes Aligning Public Tax Reporting With EU
The benefits of Australia's public country-by-country reporting bill would diminish if it were limited to jurisdictions covered by the European Union's regime, as businesses have requested, the Australian Senate's economics committee reported Friday.
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August 02, 2024
PwC Australia Names Independent Governance Board Chair
PwC Australia has chosen the first independent nonexecutive chair of its governance board, along with an independent nonexecutive board member, as it takes steps to rebound in the wake of its scandal involving the leak of government tax documents.
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August 02, 2024
Treasury Faces Complicated Path For Amount B Pricing Rules
The U.S. Treasury Department signaled it is considering how to enact the OECD's routine pricing plan known as Amount B, but U.S. tax attorneys expect a complicated compliance exercise if rulemakers establish the new transfer pricing approach.
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August 02, 2024
Coca-Cola Poised To Appeal $2.7B Tax Bill With 11th Circ.
The U.S. Tax Court signed off Friday on Coca-Cola's $2.7 billion tax bill, setting the stage for the beverage giant to appeal the liabilities and related rulings in its long-running dispute over the IRS' reallocation of the company's foreign income.
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August 02, 2024
IRS Tells Tax Court AbbVie's $1.6B Break Fee Is A Capital Loss
The Internal Revenue Service correctly reclassified AbbVie's $1.6 billion break fee to an Irish biotechnology company as a capital loss, the agency told the U.S. Tax Court, arguing that the failed merger is tantamount to disposing of property.
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August 02, 2024
Taxation With Representation: Sullivan, Dechert, Kirkland
In this week's Taxation With Representation, BNP Parabis SA acquires an investment management subsidiary for €5.1 billion, Cleveland accounting firm CBIZ merges with competitor Marcum for $2.3 billion, and Arcosa Inc. inks a deal with a family-owned construction materials business for $1.2 billion.
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August 02, 2024
Liberty Global's $110M Tax Refund Kosher, 10th Circ. Told
The IRS is trying to block Liberty Global's bid for a $110 million tax refund by improperly using a legal doctrine requiring transactions to have economic substance, the telecommunications giant told the Tenth Circuit, arguing it was allowed to make tax-driven choices in the transactions at issue.
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August 02, 2024
Top UK Court To Hear HMRC Car Park Tax Dispute With NHS
HM Revenue and Customs has been granted permission by Britain's highest court to challenge a ruling that a National Health Service trust qualified for value-added tax exemption for hospital car parking, a decision that could affect appeals brought by NHS entities.
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August 01, 2024
Divided Tax Court Says Treaty Bars Collections Hearing
A divided U.S. Tax Court ruled Thursday that it lacked authority to review an Internal Revenue Service decision preventing a woman from challenging a federal tax lien the agency issued on behalf of the Canadian government to secure her tax debt to that country.
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August 01, 2024
Coca-Cola, IRS Enter $2.7B Tax Bill In Transfer Pricing Dispute
Coca-Cola and the IRS submitted tax liability calculations totaling $2.73 billion to the U.S. Tax Court, reflecting the latest step in the company's long-running transfer pricing dispute over the agency's reallocation of the company's foreign affiliate income.
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August 01, 2024
EU Seeking Input On Electronic Country-By-Country Reporting
The European Commission is looking for feedback on draft regulations creating a common template and electronic format for country-by-country reporting forms that large multinational corporations operating in the European Union will be required to use to disclose their corporate taxes, the EU's executive arm said Thursday.
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August 01, 2024
Airbnb's $1.3B Bill From IRS Overvalues IP, Tax Court Told
Airbnb is challenging a $1.3 billion tax bill tied to income the IRS allocated from overseas, telling the U.S. Tax Court the agency overvalued intellectual property the home-rental giant licensed to its Irish affiliate before going public.
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August 01, 2024
Australia Seeking Feedback On Nonresident Trust Guidance
The Australian Taxation Office is soliciting input on draft guidelines for compliance with the country's income tax obligations in cases where property of a nonresident trust is paid to or applied for the benefit of a resident beneficiary.
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August 01, 2024
3rd Circ. Affirms Nix Of Discovery Ask On GM In Brazil Case
A Delaware federal court didn't abuse its discretion by declining to begin discovery on General Motors to aid ongoing litigation in Brazil for a group that is entitled to receive dozens of car dealerships' tax credits from the early 1990s, the Third Circuit found.
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August 01, 2024
15 Arrested In Albanian Ring Involving Money Laundering
A "prominent money launderer" was among 15 members of what was called a high-profile Albanian organized crime group arrested by authorities under suspicion of crimes including contract killings and money laundering using cryptocurrency transactions, Europol said Thursday.
Expert Analysis
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Judicial Independence Is Imperative This Election Year
As the next election nears, the judges involved in the upcoming trials against former President Donald Trump increasingly face political pressures and threats of violence — revealing the urgent need to safeguard judicial independence and uphold the rule of law, says Benes Aldana at the National Judicial College.
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Spartan Arbitration Tactics Against Well-Funded Opponents
Like the ancient Spartans who held off a numerically superior Persian army at the Battle of Thermopylae, trial attorneys and clients faced with arbitration against an opponent with a bigger war chest can take a strategic approach to create a pass to victory, say Kostas Katsiris and Benjamin Argyle at Venable.
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What Recent Study Shows About AI's Promise For Legal Tasks
Amid both skepticism and excitement about the promise of generative artificial intelligence in legal contexts, the first randomized controlled trial studying its impact on basic lawyering tasks shows mixed but promising results, and underscores the need for attorneys to proactively engage with AI, says Daniel Schwarcz at University of Minnesota Law School.
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How FinCEN Proposal Expands RE Transaction Obligations
Against a regulatory backdrop foreshadowing anti-money laundering efforts in the real estate sector, the Financial Crimes Enforcement Network's proposed rule significantly expands reporting requirements for certain nonfinanced residential real estate transfers and necessitates careful review, say attorneys at Fried Frank.
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Litigation Inspiration: A Source Of Untapped Fulfillment
As increasing numbers of attorneys struggle with stress and mental health issues, business litigators can find protection against burnout by remembering their important role in society — because fulfillment in one’s work isn’t just reserved for public interest lawyers, say Bennett Rawicki and Peter Bigelow at Hilgers Graben.
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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.