International

  • August 06, 2024

    Ex-UBS Exec Calls $4.7M In FBAR Penalties Unconstitutional

    A former executive for Swiss bank UBS' North American group told a Connecticut federal court the $4.7 million in penalties he faces for willful failure to report his foreign bank accounts are unconstitutionally excessive.

  • August 06, 2024

    Australia Provides Thin Capitalization Rules Guidance

    The Australian Taxation Office published guidance for compliance with the country's new thin capitalization rules, including the new earnings-based tests and other provisions.

  • August 06, 2024

    OECD Tax Center Shuffling Leadership Team

    The Organization for Economic Cooperation and Development made multiple senior appointments within its Center for Tax Policy and Administration, Director Manal Corwin announced, including replacing its recently departed deputy director.

  • August 06, 2024

    Arnold & Porter Adds Abramson Cancer Center Chief Counsel

    Throughout her career and while working in progressive leadership roles for the Abramson Cancer Center at the University of Pennsylvania, Mir Masud-Elias, Arnold & Porter Kaye Scholer LLP's newest counsel, has asked herself the same question: Is this role the best use of her time on Earth?

  • August 06, 2024

    Paul Hastings Gains Tax Pro In Dallas From McDermott

    Paul Hastings announced Tuesday that its meteoric growth in Texas is continuing with the addition of a partner in Dallas who strengthens its global tax practice and came aboard from McDermott Will & Emery LLP.

  • 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.

  • 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.

  • 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.

  • 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.

  • 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.

  • 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.

  • 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.

  • 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.

  • 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.

  • 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.

  • 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.

  • 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.

  • 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.

  • 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.

  • 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.

  • 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.

  • 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.

  • 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.

  • 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.

  • 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.

Expert Analysis

  • 6 Practice Pointers For Pro Bono Immigration Practice

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    An attorney taking on their first pro bono immigration matter may find the law and procedures beguiling, but understanding key deadlines, the significance of individual immigration judges' rules and specialized aspects of the practice can help avoid common missteps, says Steven Malm at Haynes Boone.

  • Lessons From Country Singer's Personal Service Saga

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    Recent reports that country singer Luke Combs won a judgment against a Florida woman who didn’t receive notice of the counterfeit suit against her should serve as a reminder for attorneys on best practices for effectuating service by electronic means, say attorneys at Jenner & Block.

  • 7 E-Discovery Predictions For 2024 And Beyond

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    The legal and technical issues of e-discovery now affect virtually every lawsuit, and in the year to come, practitioners can expect practices and policies to evolve in a number of ways, from the expanded use of relevancy redactions to mandated information security provisions in protective orders, say attorneys at Littler.

  • 5 Litigation Funding Trends To Note In 2024

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    Over the next year and beyond, litigation funding will continue to evolve in ways that affect attorneys and the larger litigation landscape, from the growth of a secondary market for funded claims, to rising interest rates restricting the availability of capital, says Jeffery Lula at GLS Capital.

  • 4 Legal Ethics Considerations For The New Year

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    As attorneys and clients reset for a new year, now is a good time to take a step back and review some core ethical issues that attorneys should keep front of mind in 2024, including approaching generative artificial intelligence with caution and care, and avoiding pitfalls in outside counsel guidelines, say attorneys at HWG.

  • What The Law Firm Of The Future Will Look Like

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    As the legal landscape shifts, it’s become increasingly clear that the BigLaw business model must adapt in four key ways to remain viable, from fostering workplace flexibility to embracing technology, say Kevin Henderson and Eric Pacifici at SMB Law Group.

  • 4 PR Pointers When Your Case Is In The News

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    Media coverage of new lawsuits exploded last year, demonstrating why defense attorneys should devise a public relations plan that complements their legal strategy, incorporating several objectives to balance ethical obligations and advocacy, say Nathan Burchfiel at Pinkston and Ryan June at Castañeda + Heidelman.

  • Unpacking The Proposed Production Tax Credit Regulations

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    Recently proposed tax regulations for claiming the U.S. clean-energy manufacturers' production credit under Internal Revenue Code Section 45X are less stringent than many had feared but fail to define a fundamental eligibility requirement, say Casey August and Jared Sanders at Morgan Lewis.

  • 10 Considerations For Litigating A New York Tax Case

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    While some of New York’s recently adopted corporate tax regulations are likely to face legal challenges, aggrieved taxpayers should answer certain questions before deciding to embark on the tax litigation process, say Cyavash Ahmadi and Jeffrey Friedman at Eversheds Sutherland.

  • Law Firm Strategies For Successfully Navigating 2024 Trends

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    Though law firms face the dual challenge of external and internal pressures as they enter 2024, firms willing to pivot will be able to stand out by adapting to stakeholder needs and reimagining their infrastructure, says Shireen Hilal at Maior Consultants.

  • Attorneys' Busiest Times Can Be Business Opportunities

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    Attorneys who resolve to grow their revenue and client base in 2024 should be careful not to abandon their goals when they get too busy with client work, because these periods of zero bandwidth can actually be a catalyst for future growth, says Amy Drysdale at Alchemy Consulting.

  • How Attorneys Can Be More Efficient This Holiday Season

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    Attorneys should consider a few key tips to speed up their work during the holidays so they can join the festivities — from streamlining the document review process to creating similar folder structures, says Bennett Rawicki at Hilgers Graben.

  • How Clients May Use AI To Monitor Attorneys

    Excerpt from Practical Guidance
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    Artificial intelligence tools will increasingly enable clients to monitor and evaluate their counsel’s activities, so attorneys must clearly define the terms of engagement and likewise take advantage of the efficiencies offered by AI, says Ronald Levine at Herrick Feinstein.

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