International
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January 21, 2025
Skadden Hires Tax Pro In London From Baker McKenzie
Skadden Arps Slate Meagher & Flom LLP has hired a former Baker McKenzie partner to serve in the firm's tax group in London.
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January 21, 2025
Expat Facing $6.9M In FBAR Penalties, Interest
An American woman living in Switzerland faces $6.9 million in penalties, interest and late fees because she did not report her accounts that were held at a Swiss bank, the U.S. government told a D.C. federal court.
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January 21, 2025
UK Waste Management Co. Denies Ties To £2.2M Tax Scam
A U.K. waste management company denied involvement in a scheme to reduce tax rates that put a business affiliate on the hook for £2.2 million ($2.7 million), contending that the affiliate failed to detect red flags.
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January 21, 2025
Sweden Considering Wind Turbine Property Tax Hike
Sweden is considering increasing the property tax on wind turbines to 0.5% of their assessed value from the current 0.2% starting in 2026, the country's Ministry of Finance said Tuesday.
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January 21, 2025
EU Officials Still Committed To Global Tax Deal Without US
The European Union remains committed to the global tax deal signed by over 130 countries in 2021 even after President Donald Trump announced the U.S. would no longer participate in the agreement, according to EU officials speaking in Brussels on Tuesday.
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January 21, 2025
Justices Decline To Review NY Tax On IBM, Disney Royalties
The U.S. Supreme Court declined Tuesday to hear claims from Disney and IBM that New York's former method of taxing royalty payments from foreign affiliates resulted in unconstitutional discrimination against interstate commerce.
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January 21, 2025
HMRC Wins Appeal In £197M BlueCrest Tax Battle
A London appeals court has sent a challenge by British-American hedge fund BlueCrest to a demand from HM Revenue and Customs for approximately £197 million ($242 million) in tax back to a lower tribunal for fresh consideration.
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January 17, 2025
Law360 Names Practice Groups Of The Year
Law360 would like to congratulate the winners of its Practice Groups of the Year awards for 2024, which honor the attorney teams behind litigation wins and significant transaction work that resonated throughout the legal industry this past year.
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January 17, 2025
Law360 Names Firms Of The Year
Eight law firms have earned spots as Law360's Firms of the Year, with 54 Practice Group of the Year awards among them, steering some of the largest deals of 2024 and securing high-profile litigation wins, including at the U.S. Supreme Court.
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January 20, 2025
Gov't Gets Mixed Reception On Inheritance Tax Pension Plans
Proposals by the U.K. government to bring pension assets within the scope of inheritance tax will result in "numerous problems" and raise concerns in their current form, a trade body and consultants warned on Monday.
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January 17, 2025
UK Parliament Calls New Treasury Unit 'Poorly Defined'
A new HM Treasury office set up to scrutinize fiscal policy lacks staff and its purpose is poorly defined, which means it could duplicate the work of other organizations, the U.K. Parliament's Treasury Select Committee said in a report Sunday.
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January 17, 2025
US Guidance On Amount B Carries Potential For Disputes
Recent IRS guidance on a simplified and streamlined transfer pricing method for certain cross-border transactions, known as Amount B, suggests rulemakers want feedback on how it would work if it were made mandatory, but that approach could lead to controversy without global cooperation.
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January 17, 2025
Case Dismissed Against Man Accused Of Concealing Location
A former healthcare executive whose employer had accused him of avoiding CA$1.2 million ($828,000) in Canadian taxes by lying about his location no longer faces legal action, as the parties agreed to dismiss the action.
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January 17, 2025
Hawaii House Bill Seeks Worldwide Combined Reporting
Hawaii would impose a mandatory worldwide combined reporting system for corporations effective next year under a bill filed in the state House of Representatives.
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January 17, 2025
Taxation With Representation: Simpson Thacher, Covington
In this week's Taxation With Representation, Eli Lilly and Co. buys a precision breast cancer program, Applied Digital Corp. enters a financing agreement for its high-performance computing business, Clearwater Analytics buys Enfusion, and Lantheus Holdings Inc. buys Life Molecular Imaging Ltd.
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January 17, 2025
UAE, Russia Reach Agreement On Double-Tax Treaty
Representatives of the United Arab Emirates and Russia signed a draft treaty to prevent double taxation on income and capital, the UAE's state news agency said Friday, despite ongoing international tensions over Russia's war with Ukraine.
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January 17, 2025
Scottish Power Loses £28M Redress Case Against HMRC
Scottish Power lost its appeal against HM Revenue and Customs on Friday, as a tribunal ruled that the energy company was wrong to argue that just over £28 million ($34 million) in redress payments it made after being investigated for regulatory failures was tax-deductible.
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January 16, 2025
Canadian Conservatives Pledge To Kill Capital Gains Hike
The Conservative Party of Canada promised Thursday to ax a capital gains tax increase secured by the administration of outgoing Prime Minister Justin Trudeau, according to a news release shared on social media Thursday by the party's leader and its candidate for Trudeau's position, Pierre Poilievre.
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January 16, 2025
OECD's Global Minimum Tax Takes Effect In Indonesia
Indonesia began implementing the OECD's global minimum tax on multinational entities making over €750 million ($773 million) annually at the start of this year, the country's Ministry of Finance said Thursday.
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January 16, 2025
OECD To Release List Of Abusive Transactions Under Pillar 2
The Organization for Economic Cooperation and Development is putting together a list of intercompany transactions that may raise red flags as attempts to undermine an international minimum tax agreement known as Pillar Two, an OECD official said Thursday.
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January 16, 2025
Madeira Loses EU State Aid Case Over Tax Breaks
Portugal will have to recover money from companies granted reduced tax rates by its autonomous territory Madeira because the taxpayers failed to meet the terms of two European Commission decisions allowing state aid, the European Court of Justice ruled Thursday.
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January 16, 2025
Morrison Foerster Adds Tax Group Co-Chair From Jones Day
Morrison Foerster LLP announced it has added a partner from Jones Day to serve as co-chair of the firm's global tax group in its New York office.
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January 16, 2025
HMRC Cuts Response Time To Tax Info Exchange Requests
HM Revenue & Customs dropped its average response time to international information exchange requests to 127 days from 175 days, well below the international average of 180 days, the U.K. revenue agency said.
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January 16, 2025
IRS Corrects Simplified Foreign Currency Rules
The Internal Revenue Service issued corrections Thursday to finalized regulations that aim to simplify aspects of how corporations determine taxable income or loss with respect to certain affiliates that conduct business in a foreign currency.
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January 16, 2025
Treasury Updates Bonus Energy Tax Credit Safe Harbors
The U.S. Treasury Department provided updates Thursday to safe harbors that clean energy project developers can use to qualify for bonus tax credits for domestically sourcing steel and aluminum parts in response to new trade restrictions on solar products from China by President Joe Biden's administration.
Expert Analysis
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Striking A Balance Between AI Use And Attorney Well-Being
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
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
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
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.
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Congress Can And Must Enact A Supreme Court Ethics Code
As public confidence in the U.S. Supreme Court dips to historic lows following reports raising conflict of interest concerns, Congress must exercise its constitutional power to enact a mandatory and enforceable code of ethics for the high court, says Muhammad Faridi, president of the New York City Bar Association.
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What To Make Of Dueling Corporate Transparency Act Rulings
Although challenges to the Corporate Transparency Act abound — as highlighted by recent federal court decisions from Alabama and Oregon taking opposite positions on its constitutionality — the act is still law, so companies should comply with their filing requirements or face the potential consequences, say attorneys at Lowenstein Sandler.
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The Pop Culture Docket: Justice Lebovits On Gilbert And Sullivan
Characters in the 19th century comic operas of Gilbert and Sullivan break the rules of good lawyering by shamelessly throwing responsible critical thought to the wind, providing hilarious lessons for lawyers and judges on how to avoid a surfeit of traps and tribulations, say acting New York Supreme Court Justice Gerald Lebovits and law student Tara Scown.
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State Of The States' AI Legal Ethics Landscape
Over the past year, several state bar associations, as well as the American Bar Association, have released guidance on the ethical use of artificial intelligence in legal practice, all of which share overarching themes and some nuanced differences, say Eric Pacifici and Kevin Henderson at SMB Law Group.